STATE OF NEW JERSEY VS. L.S.
A-2523-13T2
In this case, we construe the elements of N.J.S.A. 2C:28-
4(b)(1), which at the time of trial, provided that a person
commits a disorderly persons offense if he "[r]eports or causes
to be reported to law enforcement authorities an offense of
other incident within their concern knowing that it did not
occur[.]" The legislature has since made the offense a fourth-
degree crime. See L. 2015, c. 175 (eff. Jan. 11, 2016).
Defendant reported that she was the victim of a sexual assault committed by an unknown assailant on her college campus. During the investigation, she admitted supplying false details of the events, such as the location of the crime and the identity of the assailant. Neither the municipal court judge nor the Law Division judge, however, concluded that the sexual assault had not occurred. Instead, based upon case law developed prior to enactment of our Criminal Code, the judge at the trial de novo concluded that the supplying of false details was sufficient to prove defendant's guilt beyond a reasonable doubt.
We reversed.
