The New Jersey Supreme Court recently granted certification in State v. Bennie Anderson (No. 84,365), in which the court will consider whether forfeiture of a public employee's entire pension for accepting a $300 bribe implicates the Excessive Fines clauses of the Eighth Amendment to the U.S. Constitution and Article I, Paragraph 12 of the New Jersey Constitution, and if so, what factors the courts should consider in assessing whether pension forfeiture is "excessive."