The N.J. Law Journal reports:
A 60-year-old precedent barring admission of unsigned confessions has been replaced by newer evidence rules, the state Supreme Court ruled Monday in permitting those statements to be used to refresh a witness’s memory. The Court’s unanimous decision, in State v. Gore, A-77-09, upheld a murder conviction, finding the confession admissible despite the defense lawyer’s silence at trial. The justices reached that conclusion after ruling that State v. Cleveland, 6 N.J. 316 (1951), has since been replaced by New Jersey Rules of Evidence 803(c)(5). The defendant had given both an informal and a transcribed confession, and did not review or sign the transcribed one.