New Supreme Court of New Jersey Decision – Compassionate Release Act

On January 13, 2025, the Supreme Court of New Jersey issued a decision in State v. Celestine Payne, ___ N.J. ___ (2025), addressing the application of the Compassionate Release Act (CRA), N.J.S.A. 30:4-123.51e. The Supreme Court upheld the denial of Payne’s petition for compassionate release, concluding that her crimes were extraordinarily heinous, cruel, and depraved. This decision underscores the judiciary’s discretion under the Compassionate Release Act and highlights its impact on New Jersey law.

Facts and Procedural History of the Compassionate Release Act Case

In 1991, Celestine Payne poisoned her husband to collect his $39,000 life insurance policy and then enlisted her children (age 14 and 20) and her autistic tenant, Eugene Cooper, to help her dump her husband’s body on the side of a road. She then collected his life insurance proceeds.

Payne then convinced Eugene Cooper to name her the beneficiary of a life insurance policy in his name. Once the policy was in place she arranged to have her daughter’s boyfriend kill Cooper. The boyfriend stabbed Cooper, but Cooper did not die. While Cooper was in the hospital in critical condition, Pyne went to the hospital, pretended to be his mother, and signed a do-not-resuscitate order (DNR).

Payne next enlisted her daughter to impersonate eighteen year old Tara Carter, who resided with them, to fraudulently obtain a $25,000 life insurance policy naming Payne as the beneficiary. Payne handed her daughter’s boyfriend a crowbar and convinced him to kill Tara. The boyfriend struck Tara in the back of the head four or five times, bludgeoning her to death. Payne and the boyfriend stuffed Tara’s body into a sleeping bag and dumped her in Paterson’s Eastside Park.

In 1997, Payne pled guilty and was sentenced to two concurrent life terms with 30 years’ parole ineligibility plus a consecutive 20-year term.

In November 2021, after serving twenty-six years in prison, Payne, who was seventy-one years old, petitioned for release under the Compassionate Release Act (CRA or Act), N.J.S.A. 30:4-123.51e due to her medical condition. The trial court denied her petition finding that although she met the Act’s medical and public safety requirements, her crimes involved “particularly heinous, cruel, or depraved conduct.” The Appellate Division reversed, concluding that the trial court had abused its discretion in finding that Payne’s crimes were extraordinarily heinous, cruel, or depraved. The Supreme Court reversed and reinstated the trial court’s decision.

Extraordinary Aggravating Factors in the Compassionate Release Act

The CRA gives courts the discretion to deny compassionate release despite the fact that the petitioner met the medical and public safety conditions if “one or more extraordinary aggravating factors exist,” including “particularly heinous, cruel, or depraved conduct.” State v. A.M., 252 N.J. 432 (2023). The Supreme Court held that the trial court did not abuse its discretion in finding that Payne’s conduct was exceptionally heinous, cruel, or depraved and in therefore denying compassionate release.

The Supreme Court found that Payne’s “overall course of criminal conduct between 1991 and 1995 was breathtakingly heinous, cruel, and depraved. It was also calculated, devious, and brutal.” For example, Payne’s impersonation of a victim’s mother to execute a DNR order and her solicitation of others to commit murders demonstrated calculated and cruel behavior. The Court concluded that such conduct went beyond the elements of first-degree murder, making her case truly “exceptional and rare” under the Compassionate Release Act.

Mitigating Factors Considered Under the Compassionate Release Act

The Supreme Court agreed with Payne and the ACLU that if a trial court considers the extraordinary aggravating factors raised by the State in opposing compassionate release, it must also consider significant mitigating factors raised by an inmate that point in favor of release. The trial court considered the mitigating factors, including Payne’s exemplary behavior in prison, remorse for her actions, and support from her family. However, the Court held that mitigating factors alone could not outweigh the extraordinary aggravating factors presented by the State. The decision highlights the judiciary’s duty to balance these considerations under the Compassionate Release Act.

Key Takeaways from the Compassionate Release Act Decision

The Supreme Court’s decision in State v. Celestine Payne reaffirms the importance of discretion in compassionate release cases. While the Compassionate Release Act aims to provide relief for medically vulnerable inmates, it also ensures that those whose crimes involve extraordinary aggravating factors are not automatically entitled to release. This precedent emphasizes the role of courts in balancing the interests of justice with legislative goals.

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