Search Rutgers Law Library N.J. Court Opinions

1 STATE OF NEW JERSEY v. C.D. -- rank: 1000

... to testify via a closed-circuit television as provided in N.J.S.A. 2A:84A-32.4. To meet the standards codified by the Legislature in N.J.S.A. 2A:84A-32.4(b), the State submitted a report authored by the child ... or in any action alleging an abused or neglected child.' N.J.S.A. 2A:84A-32.4(a) and (b). To approve 22 A-0055-12T2 this ... or mental distress if required to testify in open court. N.J.S.A. 2A:84A- 32.4(b) (emphasis added). The State is required to establish this ... Court upheld the constitutionality of a Maryland statute similar to N.J.S.A. 2A:84A-32.4. In State v. Crandall, 120 N.J. 649, 651 (1990 ... Supreme Court relied on Craig to uphold the constitutionality of N.J.S.A. 2A:84A-32.4. Defendant nevertheless argued before the trial judge, and continues ...

docket:	a0055-12
court:	NJ Superior Court Appellate Division
decided:	2015-08-12
status:	unpublished
citation:
Document Size:	81977

2 NEW JERSEY DIVISION OF CHILD PROTECTION AND PERMANENCY v. C.W. -- rank: 968

... the judge must adhere to the statutory procedures outlined in N.J.S.A. 2A:84A-32.4, prior to allowing in camera testimony of a child-witness ... in this matter did not conform to the requirements of N.J.S.A. 2A:84A-32.4, defendant did not object to the use of the alternate ... practice which C.W. suggests contravenes the plain language of N.J.S.A. 2A:84A-32.4, and "abrogate[s] [her] due process rights." C.W. also ... camera proceeding in lieu of the child's trial testimony. N.J.S.A. 2A:84A-32.4. Nevertheless, we determine the record reflects sufficient credible evidence, aside ... B. , 120 N.J. 112 , 126 (1990). In that regard, N.J.S.A. 2A:84A-32.4 provides the framework for taking a child's closed circuit ... we have located no decisional authority regarding the application of N.J.S.A. 2A:84A-32.4 in Title Nine actions nor have we found any ...

docket:	a0542-12
court:	NJ Superior Court Appellate Division
decided:	2014-03-27
status:	published
citation:	435 N.J.Super. 130 87 A.3d 245
Document Size:	43507

3 NEW JERSEY DIVISION OF CHILD PROTECTION AND PERMANENCY v. S.S and R.B -- rank: 943

... A-0319-19T2 2 was not conducted in accordance with N.J.S.A. 2A:84A-32.4 and violated his due process rights. We agree with the ... was not conducted in accordance with the protections afforded by N.J.S.A. 2A:84A-32.4 and New Jersey caselaw.' Rick claims the court's failure ... Bill because the interview 'was not conducted in accordance with . . . N.J.S.A. 2A:84A-32.4 and New Jersey caselaw[,]' and the court 'denied [Rick] his ... court testimony, the trial judge must follow the requisites of N.J.S.A. 2A:84A-32.4(a) to [(c)].' 435 N.J. Super. 130, 143 (App ... court testimony, the trial judge must follow the requisites of N.J.S.A. 2A:84A-32.4(a) to [(c)].' 435 N.J. Super. at 143. Rick ... a Title Nine defendant,' see ibid., and, as a result, N.J.S.A. 2A:84A-32.4 was inapplicable to the court's in camera interview ...

docket:	a0319-19
court:	NJ Superior Court Appellate Division
decided:	2021-02-04
status:	Unpublished
citation:
Document Size:	52068

4 State v. Timothy A. Smith -- rank: 869

... that under the facts of this case, the provisions of N.J.S.A. 2A:84A-32.4, and the controlling decisional law, permitting T.I. to testify ... be permitted to testify on closed circuit television pursuant to N.J.S.A. 2A:84A-32.4. That hearing was conducted on June 4, 1996.     T.I ... findings relating to the impact of the presence of each.         [ N.J.S.A. 2A:84A-32.4] It is clear that the trial court made the factual ... Although the trial court conducted the evidentiary hearing required by N.J.S.A. 2A:84A-32.4 and found that the statutory preconditions for allowing testimony on ... that is the public policy sought to be advanced by N.J.S.A. 2A:84A-32.4. With the caveat of Mattox firmly in mind, the Craig ... reject the Appellate Division's attempt to limit application of N.J.S.A. 2A:84A-32.4 to only those instances in which the child's ...

docket:	a-213-97
court:	njsupreme
decided:	1999-06-04
status:
citation:	158 N.J. 376
Document Size:	50380

5 DIVISION OF CHILD PROTECTION AND PERMANENCY v. J.B.D., Jr -- rank: 862

... conducted an in camera interview of Sally in violation of N.J.S.A. 2A:84A-32.4. Defendant did not raise this objection to Judge Berdote Byrne ... may be circumscribed by Rule 5:12- 4(b) or N.J.S.A. 2A:84A-32.4. The statute and rule limit confrontation when the witness is ... her] demeanor.' L.A., 357 N.J. Super. at 168. N.J.S.A. 2A:84A-32.4 sets forth an alternative means of securing a child-victim ... each other during the testimony by a separate audio system. [ N.J.S.A. 2A:84A-32.4(a)(1), (b), and (d).] For the first time on ... defendant argues that Sally's interview failed to comply with N.J.S.A. 2A:84A-32.4 because Judge Berdote Byrne failed to make specific findings that ...

docket:	a3364-15
court:	NJ Superior Court Appellate Division
decided:	2018-04-24
status:	unpublished
citation:
Document Size:	63945

6 NEW JERSEY DIVISION OF YOUTH AND FAMILY SERVICES v. D.D. -- rank: 855

... circuit television or a comparable video link, in accordance with N.J.S.A. 2A:84A-32.4. Consistent with our prior opinion, all counsel shall be afforded ... may be circumscribed by Rule 5:12-4(b) or N.J.S.A. 2A:84A-32.4. "Trial judges have broad discretion in abuse and neglect cases ... face-to-face confrontation is not absolute is found in N.J.S.A. 2A:84A-32.4, which sets forth an alternative means of securing a child ... each other during the testimony by a separate audio system. [ N.J.S.A. 2A:84A-32.4]. The use of the authorized statutory procedure "does not violate ... severe emotional distress if required to testify in open court." N.J.S.A. 2A:84A-32.4. D.D.'s theory is R.C. used the event ... have been made by the trial judge, and we agree N.J.S.A. 2A:84A-32.4 is inapplicable when assessing the manner to present W. ...

docket:	a4642-07
court:	NJ Superior Court Appellate Division
decided:	2009-06-01
status:	unpublished
citation:
Document Size:	56523

7 NEW JERSEY DIVISION OF CHILD PROTECTION AND PERMANENCY v. L.G. -- rank: 742

... the court failed to adhere to the procedures outlined in N.J.S.A. 2A:84A-32.4, specifically that 'there is a substantial likelihood . . . [Nina] would suffer ... the judge must adhere to the statutory procedures outlined in N.J.S.A. 2A:84A-32.4, prior to allowing in camera testimony of a child witness ...

docket:	a5333-15
court:	NJ Superior Court Appellate Division
decided:	2018-12-04
status:	Unpublished
citation:
Document Size:	49402

8 STATE OF NEW JERSEY v. E.R.-L -- rank: 742

... testify at trial by closed circuit television (CCTV) pursuant to N.J.S.A. 2A:84A-32.4 (allowing CCTV testimony at trial 'if the court determines by ...

docket:	a3188-18
court:	NJ Superior Court Appellate Division
decided:	2021-12-02
status:	Unpublished
citation:
Document Size:	51345

9 STATE OF NEW JERSEY v. A.B.M -- rank: 734

... appropriate the closed circuit television procedure authorized by the Legislature, N.J.S.A. 2A:84A-32.4), will afford the jury an opportunity to evaluate the testimony ... defendant a right of cross-examination and limited confrontation, see N.J.S.A. 2A:84A-32.4, that would be lost if the child were disqualified due ...

docket:	a4591-09
court:	NJ Superior Court Appellate Division
decided:	2012-09-25
status:	unpublished
citation:
Document Size:	51861

10 NEW JERSEY DIVISION OF CHILD PROTECTION AND PERMANENCY v. E.G and J.F -- rank: 724

... fact finding of abuse or neglect.' A-3617-19 7 N.J.S.A. 2A:84A-32. 4 AND N.J.S.A. 2A:61-B1 THEREBY VIOLATING ... significant at the time. Macon, 57 N.J. at 333. N.J.S.A. 2A:84A-32.4 addresses procedures for conducting child interviews. 3 N.J.S.A. 2A:84A-32.4(a) provides: (1) . . . in any action alleging an abused or ... witness when making testimonial statements using closed circuit television. Further, N.J.S.A. 2A:84A-32.4(b)-(d) provides: 3 N.J.S.A. 2A:61B ...

docket:	a3617-19
court:	NJ Superior Court Appellate Division
decided:	2022-02-01
status:	Unpublished
citation:
Document Size:	25499

11 STATE OF NEW JERSEY v. M.M. -- rank: 685

... to testify by way of closed-circuit television pursuant to N.J.S.A. 2A:84A-32.4. The trial court conducted a hearing on October 2, 2008 ...

docket:	a2747-09
court:	NJ Superior Court Appellate Division
decided:	2012-11-09
status:	unpublished
citation:
Document Size:	59554

12 Liberty Mutual Insurance Co. v. Land -- rank: 678

... of closed-circuit-television testimony in certain criminal prosecutions under N.J.S.A. 2A:84A-32.4). That is not to say that the Legislature cannot create ...

docket:	a-125-04
court:	njsupreme
decided:	2006-03-14
status:
citation:	*CITE_PENDING*
Document Size:	83732

13 STATE OF NEW JERSEY v. JESUS DELGADO, -- rank: 674

... juvenile victim may testify outside the courtroom via video-link. N.J.S.A. 2A:84A-32.4. Our courts and the United States Supreme Court have addressed ... procedural safeguards and requirements which must be met in applying N.J.S.A. 2A:84A-32.4 and we now address defendant's claims that those safeguards ...

docket:	a1284-98
court:	njappellate
decided:	2000-01-03
status:	published
citation:	<a href=
Document Size:	26136

14 State v. Franklin Jack Burr, II -- rank: 611

... was entered into evidence, the video was not. Ibid. (citing N.J.S.A. 2A:84A-32.4). During deliberations, the trial court granted the jury’s request ...

docket:	a-36-07
court:
decided:	2008-06-11
status:
citation:	195 N.J. 119
Document Size:	66763

15 DIVISION OF YOUTH AND FAMILY SERVICES v. E.R. -- rank: 600

... M.L.A. could not have sought the protections of N.J.S.A. 2A:84A-32.4, which allows a minor, sixteen years of age or younger ...

docket:	a5840-10
court:	NJ Superior Court Appellate Division
decided:	2012-07-10
status:	unpublished
citation:
Document Size:	26172