Wright v. New Jersey

1985-01-14

Headline: Court dismissed a federal challenge to New Jersey’s vague 'not manifestly appropriate' weapon-possession law, leaving a man’s conviction for carrying an exacto knife intact while a Justice warned of constitutional problems.

Holding: The Court dismissed the appeal for lack of a substantial federal question, leaving the New Jersey conviction and statute interpretation in place without resolving the vagueness claim.

Real World Impact:

Leaves the New Jersey conviction and weapon law in place without Supreme Court review.
Allows police and juries to apply the 'not manifestly appropriate' standard as interpreted.
Raises risk of arbitrary enforcement against ordinary people carrying everyday objects.

Topics: weapon possession, vague criminal laws, due process, police discretion, state criminal law

Summary

Background

Charles Wright, a man in New Jersey, was arrested after police found an exacto knife hidden in his sock. He was convicted under a state law that forbids possession of a weapon when it is "not manifestly appropriate" for lawful uses. An intermediate court reversed his conviction, but the New Jersey Supreme Court reinstated the conviction and upheld the statute. Wright appealed to the U.S. Supreme Court.

Reasoning

The key question raised in Justice Brennan’s dissent is whether the phrase "not manifestly appropriate" is so unclear that it violates the Fourteenth Amendment’s due process protections. Brennan notes that New Jersey courts require only that a person knowingly possess the object, not that the person intended to use it unlawfully. He argues that the statute, as read by the state courts and applied by juries and police, gives no clear standard, risks trapping innocent people, and invites arbitrary or discriminatory enforcement.

Real world impact

The Supreme Court dismissed the appeal for lack of a substantial federal question and therefore did not rule on the constitutional issue. That leaves the New Jersey conviction and the state court’s interpretation of the law in place. Justice Brennan warns this outcome preserves a vague standard that could allow police and juries to decide, case by case, what possession is unlawful.

Dissents or concurrances

Justice Brennan, joined by Justice Marshall, dissented from the dismissal and argued the case presented a substantial federal constitutional question about vagueness and the absence of a required intent.