State v. Shaquan Hyppolite (080302) (Hudson County and Statewide) - Published

When exculpatory evidence is disclosed after a detention hearing, judges should use a modified materiality standard to decide whether to reopen the hearing. If there is a reasonable possibility that the result of the detention hearing would have been different had the evidence been disclosed, the hearing should be reopened. Applying that standard in this case, the Court reverses and remands to the trial court to reopen the detention hearing.