No Error In Bow-And-Arrow Killing Trial, NJ Supreme Court Rules

CAMDEN, NJ — The New Jersey Supreme Court decided there was no trial error in the conviction of a South Jersey man who shot his sister-in-law’s ex-boyfriend with a bow and arrow, killing him.

Timothy Canfield, 35, was convicted of killing 25-year-old Kereti Paulsen with a compound bow after an argument outside a Berlin Borough home in 2013. In January 2022, an appeals court rejected most of his claims of errors in the trial. The New Jersey Supreme Court affirmed the Appellate Division’s decision on Jan. 11.

“The judgment of the Appellate Division is affirmed substantially for the reasons stated in Judge Ronald Susswein’s thoughtful and thorough opinion,” the Supreme Court judges wrote.

Canfield said the jury should have been told to consider a lesser charge of passion/provocation manslaughter, meaning he was provoked into acting and did so in the heat of passion, rather than an aggravated manslaughter charge.

Canfield claimed the 18-year prison term he is serving was an excessive sentence. He further called for a new sentencing hearing, asking the court to allow for his age to be considered as a mitigating factor (he was 25 at the time of Paulsen’s death).

Officials say Canfield shot Paulsen, of Cape May Court House, with an arrow in January of 2013, causing fatal injuries. Canfield is serving an 18-year prison term after he was convicted of aggravated manslaughter, three counts of hindering apprehension or prosecution and possession of a weapon for an unlawful purpose in 2019.

Paulsen had dated Canfield’s sister-in-law in the past and had a child with her, court records show.

Camden County prosecutors said Paulsen was walking away from a verbal argument that had involved several people when Canfield shot him. An arrow pierced a vein in Paulsen’s pelvis, and he bled to death, officials said.

Prosecutors say Canfield made a 911 call after the shooting and pretended to be Paulsen. They also said Canfield provided false information and hid the compound bow and arrows.

Canfield said he acted in self-defense because Paulsen threatened to infect him with HIV. The jury rejected that claim, according to the Camden County Prosecutor’s Office.

Canfield also said he only intended to fire a “warning shot” and that Paulsen had approached him with an object he believed to be a hypodermic needle.

The appellate court noted there was no evidence of a physical confrontation between Paulsen and Canfield before the shooting, and that Paulsen could not have come close enough to use a syringe as a weapon if he had one.

Paulsen “was, at most, armed with a syringe that might be impressed into use as a close-range weapon. Defendant, in contrast, had taken the precaution to arm himself with a compound bow that was designed to be a deadly weapon, one that could—and did—kill at distance,” the court wrote.

The Appellate Court concluded the facts did not indicate an objectively reasonable provocation and upheld the Camden County Superior Court’s conviction.

"Even accepting the credibility of defendant’s testimony, his version of the events that unfolded during the fatal confrontation fails to meet the ‘clearly-indicated’ standard as to have required a jury instruction on passion/provocation manslaughter sua sponte," the Appellate Court wrote.

The appellate judges recommended that in future murder cases involving self-defense claims, judges should consider "and make specific findings on the record" regarding whether or not to tell jurors about the passion/provocation manslaughter charge, even if neither party asks for it.

The Supreme Court was considering if the trial court should have instructed the jury on passion/provocation manslaughter in Canfield’s case, and considering the Appellate Court’s recommendation. They upheld the lower court’s decision and declined to adopt that proposed rule.

"We believe the current practice correctly balances the interests of the prosecution, the defense, and the public," the court ruled.

The Associated Press contributed to this report.