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State v. Feaster

Citations: 757 A.2d 266; 165 N.J. 388; 2000 N.J. LEXIS 1016

Court: Supreme Court of New Jersey; August 2, 2000; New Jersey; State Supreme Court

Narrative Opinion Summary

In this case, a defendant was convicted by a jury of purposeful-or-knowing murder, felony murder, and other related offenses, resulting in a death sentence for the murder of a victim during a robbery. The defendant's capital murder conviction and death sentence were affirmed by the Supreme Court of New Jersey. The court also conducted a proportionality review to evaluate the fairness of the death sentence, considering similar cases and the application of aggravating and mitigating factors. During the penalty phase, the jury weighed the aggravating factor of murder during a robbery against multiple mitigating factors, including the defendant's young age, lack of prior convictions, and mental health issues. Ultimately, the jury found the aggravating factor to outweigh the mitigating ones. The case involved the exclusion of evidence related to a separate murder indictment, and the court's analysis of the defendant's culpability included a comparison to other cases within the same category to ensure the death sentence was not disproportionate. The proportionality review took into account societal consensus, sentencing rates, and the nature of the crime compared to other similar offenses.

Legal Issues Addressed

Application of Aggravating and Mitigating Factors

Application: During the penalty phase, the jury considered the aggravating factor of the murder occurring during a robbery and several mitigating factors, ultimately concluding that the aggravating factor outweighed the mitigating ones.

Reasoning: The jury acknowledged the aggravating factor of the murder occurring during a robbery and considered some mitigating factors, including the defendant's brain disorder and his abusive family background.

Capital Murder Conviction and Sentencing

Application: The defendant was convicted of purposeful-or-knowing murder and felony murder, among other charges, and received a death sentence affirmed by the Supreme Court of New Jersey.

Reasoning: Richard Feaster was convicted of purposeful-or-knowing murder and felony murder of Keith Donaghy on March 15, 1996, by a Gloucester County jury... He received a death sentence for the capital murder conviction.

Exclusion of Evidence from Separate Indictments

Application: Evidence related to the defendant's alleged involvement in a second murder was excluded from the trial of the murder of Keith Donaghy.

Reasoning: Although charged with both, the indictments were severed, and evidence of the second murder was excluded from the trial concerning Donaghy.

Jury's Consideration of Defendant's Background

Application: The jury evaluated the defendant's background, including his age, lack of prior convictions, and mental health issues, but found these did not outweigh the aggravating factor.

Reasoning: The defendant presented ten mitigating factors, including his lack of prior convictions, his young age of twenty-two, and a history of head traumas leading to impaired judgment and impulse control.

Proportionality Review of Death Sentence

Application: The court conducted a proportionality review and found no disproportionality in the defendant's death sentence compared to similarly culpable cases.

Reasoning: Feaster requested a proportionality review of his death sentence, which the court granted, ultimately finding no disproportionality.

Prosecutorial Strategy in Capital Cases

Application: The decision to pursue non-capital charges in certain cases was influenced by the defendant's background and prior convictions.

Reasoning: A prosecutorial strategy aimed at using Loftin's prior murder conviction as an aggravating factor may have influenced the decision to pursue non-capital charges against him.