Court Discusses Evidence of Prior Crimes in New Jersey DWI Cases

Generally, when a person is charged with a DWI, the State is not permitted to introduce evidence of other crimes to support the assertion that the person committed the crime with which he or she is currently charged. Evidence of prior bad acts may be admitted for other reasons, however, as discussed in a recent New Jersey DWI case in which the State introduced evidence of the defendant’s prior car accident at his DWI trial. If you are faced with DWI charges, it is prudent to contact a vigilant New Jersey DWI defense attorney to discuss what evidence the State may try to introduce to prove your guilt at trial.

Factual Background

Allegedly, the defendant was charged with multiple crimes, including first-degree vehicular homicide for causing death while operating his vehicle while intoxicated. At trial, the State presented evidence that he dove his truck through a police barricade and into an open-air market, and caused the victim’s death. When police arrived at the scene, the defendant stated that he blacked out and did not know what happened. He was transported to a hospital, where his consent was obtained for a blood draw for an alcohol and drug analysis. He agreed to the test and signed a consent form.

It is reported that the defendant was then taken to the police station, where he waived his Miranda rights and gave a statement where he said he purchased an aerosol product a few hours before the accident. The defendant’s blood test subsequently revealed that there was difluoroethane, which is a substance found in aerosol products, in the defendant’s blood during the accident. Prior to trial, the defendant sought to suppress evidence of a 2012 car accident and frequent purchase of aerosol products. The court denied the motion, and the defendant was convicted as charged, after which he appealed, arguing in part that the trial court erred in denying his motion to suppress.

Evidence of Prior Crimes in New Jersey DWI Cases

Under the New Jersey Rules of Evidence, evidence that is relevant is presumptively admissible.  It may be deemed inadmissible, however, if the risk of undue prejudice substantially outweighs the probative value. Additionally, the Rules of Evidence provide that evidence of other crimes, acts, or wrongs are not admissible to show that a person committed a subsequent crime. It may be admitted, however, to demonstrate motive, intent, absence of a mistake, opportunity, plan, or knowledge. In determining whether evidence relates to other crimes and is subject to analysis, or, whether it is evidence that is intrinsic to the charged crime and therefore must only be relevant, a court must assess whether the evidence directly proves the charged crime or evidence of bad acts performed at the same time as the alleged crime that proves the commission of the charged crime.

In the subject case, the court found that evidence of the prior accident and plaintiff’s purchases of aerosol products was intrinsic in that it intertwined with the fabric of the case and was needed for the proper context of the crime. Specifically, it demonstrated the absence of a mistake during the commission of the alleged crimes. Thus, the court affirmed the trial court ruling.

Meet with a Dedicated New Jersey DWI Defense Attorney

If you are faced with accusations you committed a DWI offense, it is in your best interest to meet with a dedicated New Jersey DWI defense attorney regarding your options. The seasoned attorneys of the Law Offices of Jonathan F. Marshall can advise you of your rights and assist you in developing a course of action that will help seek a successful result under the facts of your case. We can be reached through the online form or at 877-450-8301 to schedule a meeting.

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