State of New Jersey v. Eric Patterson

CourtNew Jersey Superior Court Appellate Division
DecidedJune 17, 2026
DocketA-2228-23
StatusUnpublished

This text of State of New Jersey v. Eric Patterson (State of New Jersey v. Eric Patterson) 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
State of New Jersey v. Eric Patterson, (N.J. Ct. App. 2026).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-2228-23

STATE OF NEW JERSEY,

Plaintiff-Respondent,

v.

ERIC PATTERSON,

Defendant-Appellant. _________________________

Submitted October 29, 2025 – Decided June 17, 2026

Before Judges Smith and Berdote Byrne.

On appeal from the Superior Court of New Jersey, Law Division, Hudson County, Indictment No. 16-09-1175.

Jennifer N. Sellitti, Public Defender, attorney for appellant (John J. Bannan, Designated Counsel, on the brief).

Wayne Mello, Acting Hudson County Prosecutor, attorney for respondent (Patrick F. Galdieri, II, Assistant Prosecutor, on the brief).

Appellant filed a supplemental brief on appellant's behalf. PER CURIAM

Defendant Eric Patterson appeals a February 22, 2024 order denying his

petition for post-conviction relief (PCR) without an evidentiary hearing. While

impaired, Patterson drove his girlfriend's car across a traffic divide and onto a

sidewalk, striking and killing two high school students and injuring a third.

Patterson pled guilty to two counts of vehicular homicide and one count of

assault by auto. The trial court sentenced him to consecutive twelve-year terms

for the vehicular homicide charges, and a consecutive five-year term of

incarceration for assault by auto. Defendant contends plea counsel was

ineffective for not filing a motion to suppress the results of the State's

warrantless blood and urine tests. We affirm for the reasons that follow.

I.

We recite the relevant facts and procedural history from State v. Patterson

(Patterson II), No. A-1875-19 (App. Div. Feb. 28, 2022) (slip op. at 3-4):

On March 5, 2016, Patterson, age twenty-three at the time, bought and ingested phencyclidine (PCP), then drove his girlfriend's car from Jersey City towards North Bergen. While driving under the influence of PCP, he disregarded several stop signs and red lights. Patterson struck pedestrians Noel Herrera, Bryan Rodriguez, and Manuel Sanchez near Union High School when he crossed the solid double-yellow line and drove on the sidewalk. Herrera and Rodriguez died

A-2228-23 2 as a result of the accident and Sanchez sustained a broken leg.

After the accident, defendant was taken to the hospital emergency room,

where he was interviewed by two officers, Sergeant Edward Sellick of the

Hoboken Police Department and Sergeant Toni-Ann Sisk of the Hudson County

Sheriff's Office. Sgt. Sellick had defendant perform a series of field sobriety

tests. Defendant passed one test, the Romberg test, but demonstrated signs of

impairment while performing the other tests. Sgt. Sellick made several

observations of defendant, from his answers to questions about the accident to

his poor performance on the sobriety tests, that caused him to conclude that

defendant was under the influence of drugs. The detectives gave defendant a

Miranda1 warning, then defendant consented to providing a blood and urine

sample. Sgt. Sisk, in her incident report form, testified to her efforts to obtain

defendant's consent to provide the sample:

I then asked Mr. Patterson if he would voluntarily consent to giving a sample of his blood and a sample of his urine for testing. Mr. Patterson said he would. I then went over the Consent Form For Use By [L]aw Enforcement Officers When Requesting Consent to Obtain and Test Urine and the Consent Form For Use By Law Enforcement Officers When requesting to Draw and Test Blood with Mr. Patterson. Mr. Patterson consented to giving samples of his blood and urine for

1 Miranda v. Arizona, 384 U.S. 436 (1966). A-2228-23 3 testing and signed both forms. Sgt. E. Sellick served as the witness of his consent and signatures. Mr. Patterson was taken into an adjacent restroom . . . where he provided a urine sample. The container with the urine sample was secured . . . .

....

. . . [A nurse] . . . drew Mr. Patterson's blood sample . . . .

After defendant pleaded guilty to the three charges, the court imposed

consecutive sentences. On defendant's direct appeal, we reversed and remanded

to the trial court for findings with respect to the imposition of consecutive

sentences. State v. Patterson (Patterson I), No. A-4340-17 (App. Div. Jan. 9,

2019). On remand, the trial court again imposed consecutive sentences, relying,

in part, on our opinion in State v. Locane, 454 N.J. Super. 98 (App. Div. 2018).

Defendant appealed again, this time contending the trial court erred by:

applying a rebuttable presumption in favor of consecutive sentences; improperly

conducting its aggravating and mitigating factors analysis; and misapplying

Yarbough2. Defendant also contended that resentencing was warranted because

the Legislature had recently adopted a youth mitigating factor, which defendant

2 State v. Yarbough, 100 N.J. 627 (1985).

A-2228-23 4 argued should apply retroactively to his case. We rejected defendant's claims

on this second direct appeal and affirmed. 3 Patterson II, slip op. at 15, 20, 22.

On September 30, 2022, defendant filed his PCR petition. Defendant

argued trial counsel was ineffective for not moving to suppress the results of

defendant's warrantless blood and urine screens, which indicated positive for

PCP. On February 22, 2024, the PCR court heard argument. In a written order,

the court denied the petition without an evidentiary hearing, stating in part:

This court finds [p]etitioner's argument is without merit. There is no evidence that the [p]etitioner was so impaired as to render him incapable of knowingly and voluntarily consenting to have his blood drawn[.] Petitioner willingly signed consent forms to have his blood drawn and a urine sample obtained. His statements to Sergeant Sisk and [Sergeant] Sellick, while not entirely consistent, sufficiently demonstrate to this [c]ourt [that they] were intelligent and responsive.

Nonetheless, . . . Sellick testified . . . that when he interviewed the [p]etitioner at the hospital on the night of the incident[,] he rambled, was incoherent at times, unable to formulate complete sentences, and laughed about the crash. Furthermore, [p]etitioner failed three of four psychophysical tests, had clinical symptoms of impairment, and signs of [PCP] ingestion . . . . Based on these findings, Sergeant Sellick opined that [p]etitioner was under the influence . . . .

3 In Patterson II, we noted that Locane's inapplicability did not affect our holding affirming the trial court. Patterson II, slip op. at 17-20. A-2228-23 5 Furthermore, [p]etitioner's drug evaluation revealed PCP in both his blood and urine.

However, the [p]etitioner also was fully aware he was at the hospital, [had] sustained injuries due to a car crash, and knew that he had earlier been at his girlfriend's house and went to a liquor store. . . . Based on [p]etitioner's details of the events [of] the evening of the accident, along with his self-serving omission of details of the accident itself, this [c]ourt is clearly convinced [petitioner's] faculties were not so impaired that he could not knowingly and voluntarily consent to these samples.

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Related

Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
State v. Cummings
728 A.2d 307 (New Jersey Superior Court App Division, 1999)
State v. Harris
859 A.2d 364 (Supreme Court of New Jersey, 2004)
State v. Fritz
519 A.2d 336 (Supreme Court of New Jersey, 1987)
State v. Wade
190 A.2d 657 (Supreme Court of New Jersey, 1963)
State v. Yarbough
498 A.2d 1239 (Supreme Court of New Jersey, 1985)
State v. Dolly
605 A.2d 238 (New Jersey Superior Court App Division, 1991)
State v. Carty
806 A.2d 798 (Supreme Court of New Jersey, 2002)
State v. Johnson
346 A.2d 66 (Supreme Court of New Jersey, 1975)
State v. Carty
790 A.2d 903 (Supreme Court of New Jersey, 2002)
State v. Preciose
609 A.2d 1280 (Supreme Court of New Jersey, 1992)
State v. O'NEAL
921 A.2d 1079 (Supreme Court of New Jersey, 2007)
State v. Sugar
495 A.2d 90 (Supreme Court of New Jersey, 1985)
State v. Elders
927 A.2d 1250 (Supreme Court of New Jersey, 2007)
State v. Domicz
907 A.2d 395 (Supreme Court of New Jersey, 2006)
State of New Jersey v. Alice O'Donnell
89 A.3d 193 (New Jersey Superior Court App Division, 2014)
State of New Jersey v. Edward Holland
158 A.3d 597 (New Jersey Superior Court App Division, 2017)
State v. Locane
184 A.3d 495 (New Jersey Superior Court App Division, 2018)
State v. Nash
58 A.3d 705 (Supreme Court of New Jersey, 2013)

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State of New Jersey v. Eric Patterson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-new-jersey-v-eric-patterson-njsuperctappdiv-2026.