New Jersey Supreme Court Decision – Evidence in Criminal Trials 

Introduction to the New Jersey Supreme Court Decision 

On December 18, 2024, the New Jersey Supreme Court decided State v. Fuquan K. Knight and State v. Shaquan K. Knight, ___ N.J. ___ (2024). This important decision addressed whether juries could review surveillance video evidence in slow motion during deliberations. The ruling affirmed that trial courts have discretion to allow such replays under judicial supervision, ensuring fair evaluation of evidence without distortion.  

Facts and Procedural History of the New Jersey Supreme Court Decision 

In October 2018, a robbery occurred behind a deli in Essex County, leading to charges against Fuquan and Shaquan Knight. The key evidence presented was a six-second surveillance video showing fleeting images of the alleged perpetrators through a partially obscured deli door window. During the trial, the video was shown multiple times, including in slow motion. When the jury requested to view the video again in slow motion during deliberations, the trial court granted the request under strict supervision. The defendants were convicted, and their appeal centered on the admissibility of slow-motion playback. 

Key Legal Issues in the New Jersey Supreme Court Decision 

The New Jersey Supreme Court analyzed whether slow-motion replays constitute an alteration of evidence. In a per curium decision the Court affirmed the Appellate Division’s judgment substantially for the reasons expressed in the Honorable Jack M. Sabatino’s comprehensive opinion, State v. Fuquan K. Knight, 477 N.J. Super. 400 (App. Div. 2023). The Supreme Court affirmed that basic video playback adjustments, such as slow motion, are acceptable tools for aiding juror comprehension. It distinguished these techniques from advanced forensic methods that require expert testimony, emphasizing that slowing a video does not change its content. 

Factors for Evaluating Video Playback Requests in New Jersey Trials 

The Court endorsed guidelines for trial courts to consider jury requests for video replays: 

  • Is the video hard to discern at normal speed? 
  • Does it aid in resolving disputes over identification or intent? 
  • Does repeated playback risk prejudicing the jury due to distressing content? 

By applying these considerations, courts can balance the need for juror clarity with the defendant’s right to a fair trial. 

Safeguards and Recommendations in the New Jersey Supreme Court Decision 

The New Jersey Supreme Court also agreed with Judge Sabatino’s recommendation that the Model Criminal Jury Charge Committee include a model jury instruction to prevent undue emphasis on video evidence during deliberations. This charge would remind jurors to weigh all evidence equally and not disproportionately focus on surveillance footage. 

Conclusion: Key Takeaways from the New Jersey Supreme Court Decision 

The New Jersey Supreme Court decision in State v. Fuquan Knight confirms that slow-motion video playback is a permissible and effective tool to aid jury deliberations when carefully supervised. This ruling provides clarity for courts and practitioners handling complex evidentiary issues, reinforcing the importance of balancing juror comprehension with fairness in criminal trials. 

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