Prior Inconsistent Statement New Jersey

In State v. Gross, 121 N.J. 1, 7-9, 577 A.2d 806 (1990), the Court agreed with the fifteen factors the Court articulated for proper evaluation of the reliability of a prior inconsistent statement: (1) the declarant's connection to and interest in the matter reported in the out-of-court statement; (2) the person or persons to whom the statement was given; (3) the place and occasion for giving the statement; (4) whether the declarant was then in custody or otherwise the target of investigation; (5) the physical and mental condition of the declarant at the time; (6) the presence or absence of other persons; (7) whether the declarant incriminated himself or sought to exculpate himself by his statement; (8) the extent to which the writing is in the declarant's hand; (9) the presence or absence, and the nature of, any interrogation; (10) whether the offered sound recording or writing contains the entirety, or only a portion of the summary, of the communication; (11) the presence or absence of any motive to fabricate; (12) the presence or absence of any express or implicit pressures, inducement or coercion for making the statement; (13) whether the anticipated use of the statement was apparent or made known to the declarant; (14) the inherent believability or lack of believability of the statement; (15) the presence or absence of corroborating evidence. State v. Gross, supra, 121 N.J. at 10, 577 A.2d 806.