State v. Denofa

Defendant John A. Denofa was convicted by a jury of murder. The Appellate Division overturned the conviction because the trial court did not require a jury finding that the crime was committed in New Jersey. In this appeal, we must determine whether territorial jurisdiction is an element of the crime of murder and must be charged to the jury, even absent a request by defendant. Additionally, we must decide whether there is sufficient evidence in the record to support a finding that defendant murdered the victim in this State. We now hold that territorial jurisdiction is an offense element and…