Court Filings

The New Jersey Supreme Court held that historical cell site location information (CSLI) involves technical and specialized knowledge and therefore must be presented to a jury by a qualified expert under N.J.R.E. 702. The case arose from defendant Jule Hannah’s murder conviction where a detective testified as a lay witness mapping cell towers from phone records; the Appellate Division had reversed, and the Supreme Court affirmed that reversal. The Court found CSLI interpretation goes beyond ordinary juror knowledge, that the detective’s lay testimony and the prosecutor’s closing remarks risked misleading the jury, and that limiting instructions were insufficient to cure the error.

The Appellate Division affirmed Eric T. Seddens's convictions for aggravated manslaughter, unlawful possession of a weapon, and automobile theft. The main issue was whether the trial court properly admitted evidence of an aggravated assault Seddens committed against the same victim in 2018 under Rule 404(b) to prove motive and identity for the 2020 killing. The court held the prior assault was highly probative of motive (retaliation after his 2018 prosecution and imprisonment) and probative of identity (multiple shared characteristics of the two attacks). The trial court properly balanced prejudice against probative value, gave limiting instructions, and did not need to further sanitize the evidence.