Jean Clau S. Wright v. New Jersey State Parole Board

CourtNew Jersey Superior Court Appellate Division
DecidedOctober 29, 2025
DocketA-2328-24
StatusUnpublished

This text of Jean Clau S. Wright v. New Jersey State Parole Board (Jean Clau S. Wright v. New Jersey State Parole Board) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jean Clau S. Wright v. New Jersey State Parole Board, (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited . R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-2328-24

JEAN CLAU S. WRIGHT, a/k/a JEAN CLAUDE S. WRIGHT, JEAN-CLAUDE WRIGHT, JEANCLAUDE S. WRIGHT, JEAN WRIGHT, and JEAN C. WRIGHT,

Appellant,

v.

NEW JERSEY STATE PAROLE BOARD,

Respondent. _________________________

Argued October 9, 2025 – Decided October 29, 2025

Before Judges Marczyk, Bishop-Thompson and Puglisi.

On appeal from the New Jersey State Parole Board.

Cody T. Mason, Deputy Public Defender II, argued the cause for appellant (Jennifer N. Sellitti, Public Defender, attorney; Cody T. Mason, of counsel and on the briefs). Christopher C. Josephson, Deputy Attorney General, argued the cause for respondent (Matthew J. Platkin, Attorney General, attorney; Janet Greenberg Cohen, Assistant Attorney General, of counsel; Christopher C. Josephson, on the brief).

PER CURIAM

Appellant Jean-Claude Wright appeals from an April 2, 2025 final

decision of the New Jersey State Parole Board (Board) declining to address his

administrative appeal for lack of jurisdiction. We reverse and remand.

A jury convicted Wright of two counts of first-degree robbery, N.J.S.A.

2C:15-1(a); second-degree possession of a weapon for an unlawful purpose,

N.J.S.A. 2C:39-4(a); third-degree terroristic threats, N.J.S.A. 2C:12-3(a); and

two counts of fourth-degree aggravated assault, N.J.S.A. 2C:12-1(b)(4). For

each robbery conviction, Wright was sentenced to eleven years in prison with

an eighty-five percent parole ineligibility term and a five-year mandatory parole

supervision (MPS) term, pursuant to the No Early Release Act (NERA), N.J.S.A.

2C:43-7.2. The sentences were imposed concurrently and the remainder of the

convictions merged into the robbery convictions.

On November 20, 2018, Wright completed his maximum term of

incarceration and was released to the custody of Immigration and Customs

Enforcement (ICE). He remained in ICE custody until December 1, 2021, when

A-2328-24 2 he was released into the community and, according to the Board, began serving

his five-year MPS term.

On February 3, 2025, Wright's counsel emailed a Board staff member

inquiring about the commencement date of the MPS term. Wright argued the

MPS term should not have been tolled because ICE custody is civil detention.

He stated the MPS term should have expired on November 20, 2023, and any

extension of the MPS term beyond that date violated his constitutional rights

under State v. Njango, 247 N.J. 533 (2021). Therefore, Wright requested the

Board recalculate the term and immediately terminate his MPS.

On February 5, 2025, a staff member from the Board's Legal Unit

responded to the email, explaining:

Regarding your inquiry as to the commencement date of [Wright's] period of mandatory supervision, be advised that the Department of Law and Public Safety- Division of Law provided legal advice to the effect that the period of [MPS] is to be served in the community and that if an offender remains in custody following the completion of a sentence imposed pursuant to [NERA], whether the continued confinement is criminal in nature or civil in nature is not determin[ative], the service of the period of [MPS] remains tolled until the offender is released to the community.

In another email sent that day, the staff member advised that the

Department of Corrections (DOC) was responsible for the calculation of an

A-2328-24 3 offender's MPS expiration date, not the Board. Thus, Wright's counsel was

directed to send any inquiries regarding the MPS expiration date to the DOC's

Classification Services office.

The next day, Wright's counsel emailed the DOC's Classification Services

office, reasserting the MPS term should not have been tolled during the period

he spent in ICE custody, and therefore, the term expired on November 20, 2023.

On February 10, 2025, the director of Classification Services responded, stating

the issue raised in the email was a question of "MPS application," not maximum

sentence date. The director acknowledged the DOC's responsibility to calculate

both the maximum release date of a custodial term and the expiration of an MPS

term, but the MPS expiration date "is contingent upon the Actual Supervision

Begin Date provided by the [Board]."

Wright's counsel again emailed the Board's Legal Unit staff member,

advising him of the DOC's position and seeking further review of the issue. On

February 21, 2025, Wright submitted an administrative appeal to the Board

reiterating his arguments: MPS commences upon the completion of a custodial

sentence; Wright was released from DOC custody on November 20, 2023; his

MPS term should not have been tolled during civil detention by ICE; and his

MPS term therefore exceeded the imposed sentence. Wright requested the

A-2328-24 4 Board correct the commencement date of his MPS term and communicate the

date to the DOC, which would result in immediate termination of Wright's MPS.

On April 2, 2025, the Board issued a letter decision advising Wright it

"declined to consider the merits of" the administrative appeal because "the

Board ha[d] no jurisdiction to consider" it. The Board noted the DOC was

responsible for computing an offender's maximum sentence date and MPS term

expiration date and instructed Wright to direct his concerns to the DOC.

This appeal followed, wherein Wright reprises the substantive arguments

he raised in his administrative appeal. Having reviewed the record and

considered arguments of counsel, we are convinced the Board erred in rejecting

Wright's administrative appeal for lack of jurisdiction.

"Appellate review of a ruling on jurisdiction is plenary because the

question of jurisdiction is a question of law." Rippon v. Smigel, 449 N.J. Super.

344, 358 (App. Div. 2017). However, review of the "'factual findings with

respect to jurisdiction' is only to determine if those findings are supported by

substantial, credible evidence in the record." Ibid. (quoting Mastondrea v.

Occidental Hotels Mgmt. S.A., 391 N.J. Super. 261, 268 (App. Div. 2007)).

In addition to serving a mandatory minimum term of eighty-five percent

of the sentence imposed, NERA requires a defendant to serve a five-year MPS

A-2328-24 5 for a first-degree crime or a three-year MPS term for a second-degree crime.

N.J.S.A. 2C:43-7.2(a), (c). The MPS

shall commence upon the completion of the sentence of incarceration imposed by the court . . . unless the defendant is serving a sentence of incarceration for another crime at the time the defendant completes the sentence of incarceration imposed . . . in which case the term of [MPS] shall commence immediately upon the defendant's release from incarceration. During the term of [MPS] the defendant shall remain in release status in the community in the legal custody of the Commissioner of the [DOC] and shall be supervised by the [Board] as if on parole and shall be subject to the provisions and conditions of [N.J.S.A. 30:4-123.51(b)].

[N.J.S.A. 2C:43-7.2(c).]

It is undisputed the DOC is responsible for calculating an offender's

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Related

Mastondrea v. Occidental Hotels Management
918 A.2d 27 (New Jersey Superior Court App Division, 2007)
H. James Rippon v. Leroy Smigel, Esq.
158 A.3d 23 (New Jersey Superior Court App Division, 2017)

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Jean Clau S. Wright v. New Jersey State Parole Board, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jean-clau-s-wright-v-new-jersey-state-parole-board-njsuperctappdiv-2025.