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State v. Sexton

    Citation. 160 N.J. 93,733 A.2d 1125, 1999 N.J.

    Brief Fact Summary. Appellant was convicted of reckless manslaughter. Appellant argued a mistake of fact in that he did not know the gun was loaded when he pointed it at the victim and pulled the trigger.

    Synopsis of Rule of Law. A faultless or negligent mistake will allow for a mistake of fact defense to a crime requiring recklessness.


    Facts. A friend of Appellant and Victim overheard what she described as a typical argument. The friend saw that Appellant had a gun, but did not see him shoot Victim. She heard the gun go off and Victim was killed. Appellant was found guilty of reckless manslaughter and unlawful possession of a handgun without a permit. The Appellate Court reversed the conviction and found the jury instruction regarding the charge of first- degree murder unwarranted. The Appellate Court also found that the prosecution had the burden of proving beyond a reasonable doubt Appellant’s mistake of fact defense. Appellant argued a mistake of fact defense based on his belief that the gun was Victim’s and that he had no idea that it was loaded.

    Issue. Whether mistake of fact is a defense to the charge of reckless manslaughter.

    Held. Judgment of the appellate court is affirmed.
    No person may be convicted of an offense unless each element of such offense is proven beyond a reasonable doubt. If the defendant’s ignorance or mistake makes proof of a required culpability element impossible, the prosecution will fail on its proof of the offense.

    A faultless or negligent mistake will allow for a mistake of fact defense to a crime requiring recklessness.


    Discussion. The Court focused on a discussion of whether a charge of reckless manslaughter could be subject to a mistake of fact defense. The Court answered in the affirmative and then outlined what particular mistakes would negate the culpable mental state of recklessness. The Court concluded that only faultless or negligent mistakes would negate the culpable mental state of reckless. Further, if the prosecution proves the mistake is unreasonable, the jury could find a defendant guilty of reckless manslaughter or negligent manslaughter.


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