State of New Jersey v. Sean Williams

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited . R. 1:36-3. SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-1010-25 STATE OF NEW JERSEY, Plaintiff-Appellant, v. SEAN WILLIAMS, Defendant-Respondent. Argued September 16, 2026 – Decided October 1, 2026 Before Judges Currier and Puglisi. On appeal from an interlocutory order of the Superior Court of New Jersey, Law Division, Hudson County, Indictment No. 23-01-0002. Penelope Mary Way, Assistant Prosecutor, argued the cause for appellant (Wayne Mello, Hudson County Prosecutor, attorney; Penelope Mary Way, of counsel and on the briefs). Tamar Lerer, Deputy Public Defender, argued the cause for respondent (Jennifer N. Sellitti, Public Defender, attorney; Tamar Lerer, of counsel and on the brief). PER CURIAM On leave granted, the State appeals from an October 23, 2025 order granting defendant Sean Williams's motion to hold an evidentiary hearing. Because the trial court did not abuse its discretion in ordering the hearing, we affirm. Defendant was indicted for murder and weapons offenses. The charges arose from an incident where police officers located the victim, who had been stabbed, in front of a Jersey City residence. Video surveillance showed the victim and another individual engaged in a verbal dispute prior to the stabbing. Using other surveillance footage, officers tracked defendant bicycling from the area to an apartment building, where they discovered a bicycle with apparent blood on the handlebar in the lobby. While police were in the building, defendant's mother exited her apartment and asked if they were looking for her son, whom she said had been there thirty minutes before. Detectives showed her a still photograph taken from the surveillance video, and she identified the individual in the photo as her son. Two days later, detectives located Kelley Edmond, the mother of two of defendant's children. She had known defendant since high school and saw him frequently. Detectives showed Edmond surveillance video and a still A-1010-25 2 photograph from the night of the incident. She told detectives the individual in the video "looks like" defendant and identified him in the photograph. The next day, detectives located Melanie Younger, the mother of defendant's teenage child. She advised detectives she did not communicate with defendant and had not seen him since April 2022. Detectives showed Younger a still photograph taken from the surveillance and she identified defendant. Upon notice of the State's intent to have Edmond and Younger provide identification testimony at trial, defendant moved to suppress their testimony or, in the alternative, for an evidentiary hearing. In its written opinion on the motion, the trial court determined a hearing was not required under United States v. Wade, 388 U.S. 218 (1967), because the witnesses' familiarity with defendant rendered their testimony confirmatory identification. The court also found a hearing was not necessitated by State v. Sanchez, 247 N.J. 450 (2021), because the witnesses were not law enforcement officers. Although not mandated by precedent, the court granted an evidentiary hearing "to protect [d]efendant's constitutional rights and to preserve due process" by providing defendant "a meaningful opportunity to challenge the reliability of the identifications that place him at the scene of the alleged incident." The court's Rule 2:5-1(b) amplification further explained: A-1010-25 3 The [c]ourt remains unconvinced that lay witness testimony in this case would assist the jury and is concerned it may result in improper bolstering. . . . The court exercises caution in admitting testimony that lacks substantive value and may unduly influence the proceedings. The fact in issue is whether . . . [d]efendant is depicted in the [video surveillance] photograph. Upon reviewing the [video surveillance] photograph, the individual's appearance is sufficiently clear to allow the jury to independently determine whether the person depicted is . . . [d]efendant. Testimony from two individuals identifying the individual in the photograph as [d]efendant is likely redundant and may not assist the jury in performing its function. Additionally, admitting witness testimony from individuals personally familiar with . . . [d]efendant could be improper, as it effectively invites the witnesses to make the critical identification decision on behalf of the jury. This [c]ourt concluded that an evidentiary hearing was necessary for the State to demonstrate how the proposed testimony would aid the jury without resulting in improper bolstering. The State raises a single point on appeal: THE TRIAL COURT ERRONEOUSLY GRANTED AN EVIDENTIARY HEARING IN DEFENDANT'S MOTION TO SUPPRESS LAY-WITNESS IDENTIFICATIONS. We review an order granting or denying an evidentiary hearing for an abuse of discretion. State v. Broom-Smith, 406 N.J. Super. 228, 239 (App. Div. 2009). "A trial court decision will constitute an abuse of discretion where 'the decision [was] made without a rational explanation, inexplicably departed from A-1010-25 4 established policies, or rested on an impermissible basis.'" State v. Salter, 425 N.J. Super. 504, 514 (App. Div. 2012) (alteration in original) (internal quotation marks omitted) (quoting State v. Triestman, 416 N.J. Super. 195, 202 (App. Div. 2010)). Under N.J.R.E. 701, lay witness opinion testimony is admissible if it "(a) is rationally based on the witness'[s] perception; and (b) will assist in understanding the witness'[s] testimony or determining a fact in issue." Put another way, "[l]ay opinion is admissible 'if it falls within the narrow bounds of testimony that is based on the perception of the witness and that will assist the jury in performing its function.'" Sanchez, 247 N.J. at 466 (quoting State v. Singh, 245 N.J. 1 , 14 (2021)). The trial court determined an evidentiary hearing was necessary to ensure defendant's due process rights. It noted the confirmatory identifications were "highly prejudicial" to defendant because the testimony purported not only to implicate him as the perpetrator but also placed him at the scene of the incident. While neither Wade nor Sanchez mandated the trial court to conduct an evidentiary hearing under these facts, we discern no abuse of discretion in its conclusion a hearing was nevertheless warranted. Affirmed. A-1010-25 5