In State v. Payne, (A-25-23/088925) (Decided January 13, 2025),the New Jersey Supreme Court held that the trial court did not abuse its discretion in denying Celestine Payne’s petition for release under the Compassionate Release Act (CRA or Act). According to the state’s highest court, if a trial court considers extraordinary aggravating factors raised by the State in opposing compassionate release, it must also consider significant mitigating factors raised by an inmate that point in favor of release. Nonetheless, in this case, the Court found that the trial court did not abuse its discretion in relying on the fact that Payne’s crimes were extraordinarily heinous, cruel, and depraved to deny release.
Facts of State v. Payne
In 1991, Celestine Payne poisoned her husband Alphonso Payne to collect his $39,000 life insurance policy. She then enlisted her children and a tenant who lived with her family, Eugene Cooper, to help her dump Alphonso’s body on the side of a road.
Two years later, Celestine convinced Cooper to name her the beneficiary of a life insurance policy in his name. She then had him stabbed with her kitchen knife. When Cooper did not die, Celestine went to the hospital, pretended to be his mother, and signed a do-not-resuscitate order (DNR). Celestine next enlisted her daughter Wendy Payne to pose as Wendy’s best friend, 18-year-old Tara Carter, to obtain a life insurance policy on Tara naming Celestine as the beneficiary. In 1995, she solicited Wendy’s boyfriend, Charles Pinchom, to bludgeon Tara to death. She and Pinchom stuffed Tara’s body into a sleeping bag and dumped her in a park.
After serving 26 years in prison for murder and other crimes, Celestine petitioned for release under the CRA. The trial court found she had satisfied the Act’s medical and public safety requirements. However, it denied her petition, finding, among other things, that her crimes involved “particularly heinous, cruel, or depraved conduct” and therefore satisfied the first “extraordinary aggravating factor” set forth in State v. A.M., 252 N.J. 432, 460 (2023).
In A.M., the Court held that the CRA “cannot be read to require courts to grant compassionate release” if the medical and public safety conditions are met, but stressed that “courts may not exercise discretion in a way that creates de facto categorical barriers to release and overrides legislative intent,” id. at 459. Instead, inmates who meet “the Act’s medical and public safety criteria should be granted compassionate release unless one or more extraordinary aggravating factors exist,” such as “whether an offense involved any of the following extraordinary circumstances: (1) particularly heinous, cruel, or depraved conduct; (2) a particularly vulnerable victim . . . ; (3) an attack on the institutions of government or the administration of justice; and (4) whether release would have a particularly detrimental effect on the well-being and recovery process of victims and family members.”
The Appellate Division reversed. According to the appeals court, the facts presented in the case “are often present in first-degree murder cases” and did not “rise to the level of extraordinary.”
NJ Supreme Court’s Decision in State v. Payne
The New Jersey Supreme Court reversed.It held that the trial court had not abused its discretion in finding Payne’s criminal conduct to be extraordinarily heinous, cruel, and depraved.
“The trial court’s finding that Celestine’s crimes were extraordinarily heinous, cruel, and depraved was supported by substantial evidence in the record, and the trial court’s application of extraordinary aggravating factor one was not an abuse of discretion,” Justice Wainer Apter wrote. “In addition, in denying Celestine’s petition for compassionate release, the trial court appropriately considered significant mitigating factors raised by Celestine alongside the extraordinary aggravating factors raised by the State.”
In reaching its decision, the New Jersey Supreme Court noted that, although trial courts were required to consider mitigating factors in a defendant’s case, they alone could not entitle a defendant to compassionate release in the presence of extraordinary aggravating factors. Rather, trial courts are obligated to balance the mitigating and aggravating factors.
“[I]n petitioning a court for compassionate release, the inmate bears the burden of proving she meets the Act’s medical and public safety requirements. If the State relies on one or more extraordinary aggravating factors to then oppose compassionate release, petitioners can present significant mitigating factors that point in favor of release, which the trial court must consider,” Justice Wainer Apter explained. “The existence of mitigating factors alone, however, cannot establish that an individual is entitled to compassionate release.”