State vs Ambrose A. Harris
Source: Rutgers Law
Date: March 14, 2000
J., writing for a majority of the Court.
The Supreme Court affirmed Harris' murder
conviction and death sentence in 1998. This appeal addresses Harris'
request for proportionality review of his death sentence.
On the morning of December 17, 1992, twenty-two
year old Kristin Huggins drove her red Toyota MR2 from her parents' home
in Pennsylvania to the Trenton Club in downtown Trenton to paint a
mural. When she did not return home on the 17th, her parents reported
Huggins' car was found by authorities the next
day. Her body was eventually recovered in February 1993, two months
after she disappeared. Gloria Dunn led police to the location of
Huggins' body, claiming to have seen it in a psychic vision. She also
made inquiries regarding the reward money that was being offered.
Eventually, however, police learned that Dunn was present when Huggins
was murdered. Dunn identified Harris as the murderer and provided
numerous statements concerning the circumstances surrounding the murder.
Some of those statements were inconsistent. At trial, Dunn was the
State's chief witness, providing the only direct evidence linking Harris
to the crime.
Dunn testified that she and Harris met on the
morning of December 17, 1992, to carry out their plan of robbing a
luncheonette. Harris was on a bicycle, and armed with a .22 caliber
revolver. It was raining, and Harris said he would carjack someone to
avoid walking in the rain. As they approached the Trenton Club, Huggins
drove her red MR2 into the parking lot. Harris said to Dunn, “I'm
going to get that bitch,” and followed Huggins' car to the rear
driveway of the Club. Dunn stayed in the front area of the premises.
Harris returned, driving the car with Huggins sitting in the front seat.
Dunn testified that Harris ordered her into the front seat to sit with
Huggins on her lap.
Harris drove to a deserted area under the
Southard Street Bridge in Trenton. Dunn testified that Harris was
concerned about the appearance of two African-Americans driving in a
two-passenger sport vehicle with a white female passenger. Harris forced
Huggins into the front-trunk of the car, where she was required to lie
in a fetal position. He then drove back to the Trenton Club to retrieve
his bicycle. Throughout her confinement in the trunk, Huggins pleaded
for help. This infuriated Harris, who commented to Dunn that he should
have killed Huggins earlier.
Harris returned to the area under the Southard
Street Bridge. He ordered Huggins out of the trunk and ordered her to
take off her clothes. According to Dunn, Huggins was crying and shaking
badly. Harris anally raped Huggins, despite her pleas for help. Harris
then ordered Huggins back into the trunk and contemplated his next move,
eventually deciding to kill Huggins. Harris again ordered Huggins out of
the trunk. As Huggins tried to get out, Harris shot her in the back of
her head. Harris dragged the body a short distance and hid it under a
discarded mattress. He drove to his mother's house to retrieve two
shovels. Harris returned to the crime scene, removed the mattress lying
on top of Huggins, and shot her point-blank in the face to ensure she
Harris and Dunn then dug a shallow grave and
placed Huggins' body in it face down. They covered the body with dirt
and threw some additional debris on top. Harris went through Huggins'
belongings, taking $30 in cash and her ATM card. Testimony at trial
revealed that Harris drove around in Huggins' car the remainder of the
day before abandoning it. In addition, a bank ATM security video showed
that Harris attempted to withdraw $400 from Huggins' account on December
Dunn testified that she did not immediately
notify police about what she knew because Harris repeatedly threatened
her that if she told anyone, he would come looking for her and harm
people that were close to her. The defense sought to attack Dunn's
credibility based on inconsistencies between her testimony and her
earlier statements. The defense also noted Dunn's professed involvement
in the crime, and reminded the jury that she received a reduction in
charges in exchange for her testimony. Harris never testified.
Experts testified that Huggins died as a result
of two gunshot wounds to the head. Prosecution experts opined that
Huggins may have lived as long as one hour after the first shot and ten
to thirty minutes after the second, noting that an autopsy found dirt in
her lungs. A defense expert rebutted that, testifying that Huggins died
immediately following the second shot.
Harris was arrested ten days after the murder on
an unrelated matter. At the time of Harris' arrest, the .22 caliber
pistol used during the murder of Huggins was found on Harris.
A Mercer County Grand Jury indicted Harris on
June 8, 1994, on charges that included murder, felony murder, kidnaping,
robbery, and aggravated sexual assault. The Prosecutor served notice of
the following aggravating factors in support of a death penalty
prosecution against Harris: (1) the murder was committed for the purpose
of escaping detection; and (2) the murder was committed while Harris was
engaged in the commission of robbery, kidnaping, and/or aggravated
Because of the extensive publicity, Harris
requested a change in venue from Mercer County. Ultimately, he was tried
before a jury selected from Burlington County. On February 20, 1996, the
jury found Harris guilty on all counts.
In the penalty phase, the State relied on the
evidence submitted during the guilt phase. Harris' defense attorneys
submitted 180 mitigating factors concerning Harris' early childhood and
the abuse he endured during his childhood. The trial court consolidated
all of those factors into one omnibus, catch-all mitigating factor.
Three defense experts were offered during the penalty phase, all
concluding that Harris was raised in an extremely dysfunctional family
environment. Harris' father abused his mother, later abandoning the
family. Harris' mother neglected him, and she and her boyfriend
physically abused him. At a young age, Harris became involved in violent
conduct and sexual activity, and also experimented with drugs. School
officials could not control his antisocial behavior. At one point,
Harris was diagnosed as mentally retarded and institutionalized in a
State mental hospital. Harris accumulated twelve convictions as an
adult, spending less than one year out of prison during the period from
1974 to 1992.
Harris has not shown any remorse for his
actions. Throughout the trial, he acted with contempt toward all
involved in the case, including his own attorney. During sentencing on
the non-capital offenses, Harris addressed Mr. and Mrs. Huggins and told
them they owed him an apology because of the conviction.
The jury found beyond a reasonable doubt that
the aggravating factors outweighed the omnibus mitigating factor and
sentenced Harris to death. On the non-capital charges, Harris was
sentenced to a total of two life terms plus sixty-five years, with an
eighty-two-and-one-half year parole disqualifier.
The death sentence imposed on Harris is
Questions, comments and
criticisms can be directed to: Jeff