State v. Reldan case brief

State v. Reldan case brief summary
167 N.J.Super. 595 (1979)

CASE SYNOPSIS

Defendant was charged with two first-degree murders in separate counts of a single indictment, and sought to prevent joinder of the crimes in a single trial on the basis that it was prejudicial.

DISCUSSION

• The court denied defendant's motion to sever the two offenses of first-degree murder in a single indictment to be tried in separate trials because one trial would not be prejudicial to defendant, but would maintain judicial economy. 
• The court concluded that even if the defendant took the stand to testify as to one count of murder, that fact alone was not dispositive of a motion to sever so as to divest a court of all control over the matter. 
• The court rejected defendant's argument that a joint trial would result in the jury using evidence of one of the crimes to infer a criminal disposition on the part of defendant to commit the other crime because the facts demonstrated sufficient similarity in the details of both murders to permit evidence of one murder to be introduced into evidence to show identity of the other. 
• The court based this conclusion on the fact that the manner of the two murders and of the disposal of the victims was so unusual and distinctive as to mark the crime as having been committed by a single individual. 
• The court concluded this evidence was sufficiently probative to justify its admission, and outweighed any prejudice to defendant.

CONCLUSION
The court denied defendant's motion to sever the two first-degree murder offenses and try them separately because the evidence of both murders were so unusual and sufficiently similar and probative to permit evidence of one murder to be introduced to show identity of the other.



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