State v. Muhammad, 678 A.2d 164 (N.J. 1996)

Cases | State v. Muhammad, 678 A.2d 164 (N.J. 1996) | 2018

The defendant was indicted for capital murder after attacking a girl. The defendant filed a motion with the trial court, declaring New Jersey’s victim impact statute, N.J. Stat. Ann. § 2C:11-3(6), which allows the evidence of a murder victim’s character, background, and of the impact of the murder on the victim’s survivors at the sentencing proceeding, unconstitutional under both the New Jersey and United States Constitutions. The trial court granted the defendant’s motion and declared the statute unconstitutional under both constitutions. The state filed a motion for clarification as to the question of whether the New Jersey Constitution prohibited the use of victim impact evidence during sentencing. The New Jersey Supreme Court reversed the trial court’s interpretation of N.J. Stat. Ann. § 2C:11-3(6), and held that the victim impact statute was constitutional under both the state and federal constitutions. The court remanded and allowed for the state to introduce victim impact evidence at the penalty phase of the defendant’s trial.