173 N.J. 138
801 A.2d 221
Decided July 15, 2002
Supreme Court of New Jersey · decided 2002-07-15
Cited by 62 later decisions — most recently March 2019 · most notably State v. Reddish (2004), State v. Garron (2003)
62 state decisions
Key passage — most relied on by later courts
“standing alone, has been discredited by scholars as a basis to admit otherwise inadmissible evidence”
quoted by 1 later decision, including State v. Rose
Good law ✅— No negative treatment on recordhow we know
Decided 2002-07-15
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¶1concurring.
¶2Like my colleagues, I would admit the statements made by defendant to Tracey on August 27 and 28 under N.J.R.E. 803(c)(2) and (3). I write separately to note that although the res gestae principle, standing alone, has been discredited by scholars as a basis to admit otherwise inadmissible evidence, where, as here, its use is tethered to specific Evidence Rules, it remains a useful interpretive tool.
¶3Justice LONG joins in this concurrence.