State v. Hunt

In State v. Hunt, 115 N.J. 330, 367, 558 A.2d 1259, reconsideration denied, 117 N.J. 152, 564 A.2d 873 (1989), the Court said that a co-conspirator's statement to a witness that the defendant had just killed a man on the sixth floor might have been made to obtain the witness's help in disposing of the evidence of the murder (the defendant then asked her to get the garbage bags in which they disposed of his blood-stained clothes and knives), although it might also have been made in response to the witness's inquiry about the defendant's identity and the reason he was in the co-conspirator's apartment. Despite the dual possible meanings of the statement, the Court concluded the trial court did not abuse its discretion in ruling the statement was made during the course of and in furtherance of a conspiracy to hinder apprehension. Id. at 367-68, 558 A.2d 1259. The Court held the error was harmless due to the witness's questionable credibility and the overwhelming proof of the defendant's guilt. Id. at 368-69, 558 A.2d 1259.