State v. Vallejo

Defendant was convicted of a passel of offenses arising out of the alleged kidnapping and restraint of the victim, with whom he had been in a romantic relationship. During a short trial, prior incidents of domestic violence and the existence of a restraining order against defendant were referenced by various witnesses, without objection. An immediate curative instruction was not given, although an ambiguous instruction did issue at the end of the trial. The Appellate Division determined that the N.J.R.E. 404(b) evidence was inadmissible and that the curative instruction was no model, but…