Pashman Stein Walder Hayden P.C. Secures Amicus Victory as New Jersey Supreme Court Requires Expert Testimony for CSLI Evidence
On April 16, 2026, the New Jersey Supreme Court issued an opinion that will change the way criminal trials are conducted throughout the State. In State v. Jule Hannah (A-44-24) (089819), the Court unanimously held that cell site location information (CSLI) constitutes specialized information that must be presented by expert testimony. CSLI, sometimes called historic cell site data, reflects which cell tower a phone connected to, along with other technical aspects of its use, and is frequently introduced in criminal cases to place a device within a particular area at a given time. In this case, the police officer testified to CSLI as a lay witness and was not qualified as an expert. The New Jersey Supreme Court affirmed the Appellate Division’s decision reversing the defendant’s first-degree murder conviction, finding that the admission of such testimony without expert qualification was improper.
Pashman Stein attorney Howard Pashman, through the Justice Gary S. Stein Public Interest Center, represented amicus curiae Larry E. Daniel, Executive Director of the Digital Forensics Justice Initiative. In reversing the conviction, the Court adopted amicus’ argument that only expert testimony can provide the necessary scientific context to prevent juries from being misled by CSLI evidence. This decision will have a significant impact on how this increasingly common form of evidence is introduced and evaluated in criminal trials across New Jersey.
"Cell site location information, or historic cell site data, has become an increasingly common form of evidence in criminal trials. This unanimous decision by the New Jersey Supreme Court requires that such information be presented by experts. In so doing, the Supreme Court has announced a new requirement that will affect criminal trials throughout the State. The decision protects the rights of criminal defendants and strengthens the quality of evidence that juries hear,” said Howard Pashman.
Pashman Stein Walder Hayden P.C. is proud of the results he has achieved for clients. Of course, each legal matter is unique on many levels, and past successes are not a guarantee of results in any other pending or future matters.
