The state Supreme Court on Thursday reinstated a reckless manslaughter plea, finding an appeals court erroneously required a finding the defendant knew his actions would likely lead to his victim’s death.
The 4-1 majority in State v. Campfield, A-43-11, said it was sufficient that the defendant understood that chasing his half-naked victim into the woods on a freezing winter night created a risk of death.
At the same time, the court said judges, in deciding whether to accept guilty pleas, must conduct a thorough examination to ensure defendants know the gravity of their plea and have the proofs to support it.
“We caution trial courts, prosecutors and defense counsel that it is essential to elicit from the defendant a comprehensive factual basis, addressing each element of a given offense in substantial detail,” the court said.
The defendant, Kevin Campfield of Pleasantville, admitted to trying to rob Ivory Bennett by repeatedly punching him in the head and threatening him with a gun on Jan. 17, 2006.
After Bennett fell and hit his head, Campfield said, he forced Bennett to remove most of his clothes. Bennett continued to run and Campfield followed him and fired several shots from a handgun. Bennett’s body was found drowned in a creek.
Campfield gave an in-depth statement to the police and acknowledged beating Bennett and chasing him into the woods.
He ultimately pleaded guilty to second-degree reckless manslaughter and second-degree robbery before Atlantic County Superior Court Judge Albert Garofolo and was sentenced to 15 years in prison.
The Appellate Division threw out the plea to reckless manslaughter, saying that it was not fully explained at the plea hearing that Campfield understood the risk of Bennett’s death at the time of the offense.
In reversing and reinstating the plea, the majority quoted the following exchange between Campfield’s attorney at the plea, Pleasantville solo Steven Feldman, and Campbell, after Campbell gave his version of what happened:
Feldman: “You would agree with me that the fact that [Bennett] had his clothes off on a cold night and he was drunk and you forced him to go into the wooded area was reckless on your part?”
Feldman: “And that that was a contributing cause to his death?”
Justice Anne Patterson wrote for the majority, “We hold that defendant’s admissions in his plea colloquy established an adequate factual foundation for his guilty plea to the crime of reckless manslaughter.
“Defendant admitted to the trial court that he punched his intoxicated and incoherent victim, attempted to rob him, forced him to remove his clothing on a cold January night, and chased him into a wooded area, where he died,” Patterson continued.
Patterson said Campfield satisfied the requirements of the reckless manslaughter statute, N.J.S.A. 2C:11-4, et seq., and Rule 3:9-2 in that he understood that it would be “not so unexpected or unusual” that Bennett might die.
“Defendant admitted his awareness of several facts that exacerbated the risk that Bennett would die as a result of his conduct, and those facts were relevant to both mens rea and causation,” Patterson said.
She said he conceded that Bennett was injured while being pursued, that he assaulted Bennett and that he forced Bennett to remove most of his clothing, leaving him susceptible to the winter cold.
“He admitted his awareness that Bennett, intoxicated and bleeding in the wake of a serious fall and a violent attack, was incoherent when defendant forced him to flee alone into the woods,” Patterson said.
“Indeed, defendant acknowledged that his conduct was reckless, and that it was a contributing factor in his victim’s death.”
It would have been better, Patterson added, had there been a further exploration as to whether Campfield understood all aspects of his plea, and pointed to the in-depth questioning conducted by the police.
Justice Barry Albin dissented, saying Campfield failed to give a full factual account of the crime.
“A court should not infer guilt, as the majority does here, to uphold an inadequate plea,” he said.
“Specifically, defendant never admitted that he had an awareness of a risk that by chasing Bennett into the woods he might cause Bennett’s death,” Albin added.
Campfield’s attorney on the appeal, Assistant Deputy Public Defender Diane Toscano, and Assistant Atlantic County Prosecutor Courtney Cittadini, who represented the state, declined to comment on the substance of the ruling. •