In R v. Folker 2013 N.J. No. 434 the accused was convicted of second degree murder of his common law spouse and indignity on a human body. He killed her when he threw her during a violent altercation and she struck her head. He then disposed of her body in a remote wooded area, filed a missing persons report and lied to the police, family and friends. He had no prior record and expressed remorse but the trial judge found the substantial force used in the murder and his post offence conduct particularly aggravating. His period of ineligibility was set at 15 years.
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