STATE VS. ANTHONY ROSE A-0192-11T2

STATE VS. ANTHONY ROSE

A-0192-11T2

We hold that the newly enacted forfeiture-by-wrongdoing exception to the hearsay rule, N.J.R.E. 804(b)(9), applies retroactively to wrongdoing that occurred before the new Rule's effective date of July 1, 2011, and therefore to all trials conducted thereafter. 05-03-12