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Sunday, March 30, 2008

State v. J.A.

03-06-07 A-2554-05T4

In this appeal from the denial of a post-conviction relief
petition, we hold that the Supreme Court's decision in State v.
P.H., 178 N.J. 378 (2004), that a jury may consider the timing
of a victim's disclosure of sexual abuse in assessing
credibility, and therefore disapproving the contrary holding in
State v. Bethune, 121 N.J. 137 (1990), is not to be given
complete retroactivity to encompass defendant's case on
collateral review, but is limited to pipeline retroactivity
only.