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The New Jersey Supreme Court recently diverged from the deeply rooted principle that an admission of guilt must come from the lips of defendant. In State v. Campfield (A-43-11), the defendant pleaded guilty to second-degree manslaughter and second-degree robbery. The robbery allocution was text book. Defendant, who had been drinking heavily with the victim, Ivory Bennett, acknowledged that he pursued Bennett up an apartment stairway; that Bennett fell over a railing and struck his head; and that when Bennett was in an unconscious state on the ground, the defendant went into his pockets and stole money. When Bennett recovered consciousness, the defendant punched him in the face and made him remove most of his clothes. The defendant then chased the scantily clad Bennett into the woods. That certainly was a sufficient predicate for the robbery count.

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