On March 26, 2025, the Superior Court of New Jersey, Appellate Division, vacated the New Jersey State Parole Board’s denial of parole for Robert Reldan (AKA The Charmer), an 84-year-old inmate serving a life sentence plus 30 years for the brutal murders of two women in 1975. The court remanded the case for reconsideration, concluding that the Parole Board had mischaracterized key evidence, particularly psychological risk assessments, and failed to meaningfully evaluate significant mitigating factors such as age, health, rehabilitation, and institutional conduct.
Reldan’s original crimes were especially heinous: in 1975, he garroted two women to death. At the time of his conviction, he already had a lengthy criminal history, including a 1967 rape conviction and multiple juvenile adjudications. He was also convicted of conspiracy to murder a relative, assaulting a sheriff’s officer with tear gas, escaping custody, robbery, and an attempted second escape. The sentencing court designated him a habitual offender and imposed consecutive terms: life imprisonment for one murder and a 30-year sentence for the other, along with additional time for his other convictions.
Reldan became parole-eligible in 2008, but the Parole Board has repeatedly denied his applications. In its most recent decision in 2024, the Board denied parole and imposed a 36-month future eligibility term (FET), citing the severity of his past offenses and asserting he lacked insight into his crimes. However, the Appellate Division found the Board’s reasoning to be both factually flawed and legally insufficient.
Central to the court’s decision was the Board’s mischaracterization of two expert psychological evaluations—one by Reldan’s own retained psychologist and another by the Board’s expert—both of which assessed Reldan’s risk of reoffending as “low to moderate.” Despite this consensus, the Board erroneously labeled his risk as “moderate” and treated it as an aggravating factor. The appellate court found this error significant, noting that a “low to moderate” risk, particularly in light of the inmate’s age and health, does not meet the threshold of a “substantial likelihood” of reoffending required under New Jersey’s Parole Act of 1979.
The court also criticized the Parole Board for failing to substantively engage with mitigating evidence. Although Reldan has had no disciplinary infractions since 2009, has participated in decades of counseling and anti-violence programming, and has expressed remorse for his crimes, the Board dismissed these factors without adequate analysis. The Board similarly downplayed the relevance of his age and health conditions—arthritis in both knees and hips, legal blindness, cataracts, hearing loss, and an enlarged prostate—merely acknowledging them as matters of record without explaining their bearing on his risk of recidivism.
The Appellate Division emphasized that under the 1979 Parole Act, individuals are presumptively entitled to parole unless the Board can show, by a preponderance of the evidence, that there is a substantial likelihood of future criminal behavior. It further reaffirmed that while the seriousness of a past crime may be considered, it cannot serve as the sole basis to deny parole decades later without a clear connection to current risk.
Citing Berta v. N.J. State Parole Bd. (2022), the court reiterated that boilerplate conclusions and superficial analysis cannot substitute for individualized, reasoned decision-making. The opinion also referenced Acoli v. N.J. State Parole Bd., 250 N.J. 431 (2022), in stressing that advanced age is strongly correlated with decreased risk of recidivism and must be properly weighed.
Ultimately, while the court did not order Reldan’s release, it vacated the 36-month FET and required the Parole Board to re-evaluate the case within 90 days. The Board must correct its misstatements, substantively analyze all mitigating evidence, and clearly explain any future decision in accordance with applicable law.
Source: Reldan v. N.J. State Parole Bd., 2025 N.J. Super. Unpub. LEXIS 470 (App. Div. Mar. 26, 2025).