A New Jersey appeals court today (10/20) affirmed the reckless manslaughter conviction and sentence of Carlos Bryant Jr, (DOB 10/10/86), of Glassboro NJ in the 12/18/07 fatal stabbing of 19-year-old Robert Harrell at the Williamstown NJ apartment of Bryant’s sister.
The appellate judges rejected defense arguments that the trial judge’s instructions to the jury on self-defense and her refusal to question jurors when the foreperson asked to be replaced were trial errors.
While the instructions \”may have been over-inclusive,\” there was no prejudice to the defendant, the court said in a 28-page decision.
In a brief opposing the appeal, Assistant Gloucester County Prosecutor Joseph Enos wrote that not only were the trial judge’s legal instructions not detrimental to Bryant, \”the jury charge benefited him,\” a point today’s decision also made. The instructions allowed the jury to determine whether Bryant used \”non-deadly force,\” which the judges concluded \”could only have been advantageous to defendant.\”
The appellate decision found no \”claim of juror irregularity\” requiring the trial judge to conduct an interrogation of jurors.
The appeals court also found Bryant’s eight-year prison sentence was supported by the defendant’s \”history of violence\” and the need for deterrence. The defense claim that the sentence should have considered provocation of Bryant as a factor in his favor was \”negated\” in the judge’s recitation of events, Enos said. \”You recklessly caused the death of an unarmed man, while you sister pleaded with you to leave,\” the judge told Bryant at sentencing.
Only on the issue of restitution did the appeals court order reconsideration. The $5,000 payment to the state Victims of Crime Compensation Fund for Harrell’s funeral was vacated and the judges ordered a hearing on Bryant’s ability to pay that amount.
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