State of New Jersey v. James R. Denelsback
Supreme Court of New Jersey
May 12 2016
In this case the court considered whether a defendant should be entitled to a jury trial if defendant has already committed two previous DWI offenses under N.J.S.A. 39:4-50. Among other penalties, a third or subsequent offender must be confined in a jail for a period of 180 days. 90 of these days may be in an inpatient medical rehabilitation facility. The remainder must be in a workhouse. Under current law, the court does not have any discretion to reduce this mandatory jail term.
Defendant was convicted in court. On appeal, defendant asserted that defendant should be entitled to a jury trial due to the harsh consequences of the offense. The court was tasked with determining whether the DWI constitutes a serious or petty offense under the Sixth Amendment. In particular, the Sixth Amendment requires a criminal defendant to be provided with a jury trial.
The court reasoned that DWI offenders will not be susceptible to more than six months of incarceration. Further, even though the monetary penalties arising from a third or subsequent DWI conviction may be harsh, they do not trigger the right to a jury trial. However, the court did state that any additional penalties under these circumstances would cause the court to find that defendant’s should be entitled to a jury trial. The court also reasoned that the government’s interest to promptly dispose of DWI offenses outweighs defendant’s need for a jury trial.
A full text of the court’s decision can be found by clicking here.