State v. Talley

The opinion of the Court was delivered by

CLIFFORD, J.

This appeal presents an important issue of first impression concerning the “consolidation of theft offenses” provision, N.J.S.A. 2C:20-2(a), of the Code of Criminal Justice (Code). Defendant was indicted for, inter alia, armed robbery, in violation of N.J.S.A. 2C:15-1. He was convicted of theft by deception, N.J.S.A. 2C:20-4 1 . The grand jury had received no evidence of deception, and deception is not a necessary ingredient of a robbery conviction. The question is whether despite the foregoing circumstances the “consolidation of theft…