State of New Jersey v. Linda Y. Naulty

New Jersey Superior Court Appellate Division·Decided June 11, 2026·No. A-2079-24·Unpublished

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-2079-24

STATE OF NEW JERSEY, Plaintiff-Respondent,

v.

LINDA Y. NAULTY, a/k/a KIMBERLY A. GUNDIKUNST, KIMBERLY A. JACKSON, and LINDA Y. JACKSON,

Defendant- Appellant.

Submitted January 27, 2026 – Decided June 11, 2026 Before Judges Sumners, Susswein and Augostini.

On appeal from the Superior Court of New Jersey, Law Division, Burlington County, Indictment Nos. 21-07-

0748 and 21-09-1107.

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

LaChia L. Bradshaw, Burlington County Prosecutor, attorney for respondent (Alexis R. Agre, Assistant Prosecutor, of counsel and on the brief).

PER CURIAM Defendant Linda Y. Naulty appeals the February 13, 2025 Law Division order denying her petition for post-conviction relief (PCR) without an evidentiary hearing. In November 2021, defendant pled guilty to first-degree strict liability for drug-induced death and third-degree possession of a controlled dangerous substance (CDS) with intent to distribute. Defendant's convictions arose from a February 7, 2021 incident in which she distributed drugs to an individual who then died from a fentanyl overdose. Defendant contends that her plea counsel was ineffective. After reviewing the record in light of the governing legal principles, we are constrained to reverse and remand for an evidentiary hearing to further explore defendant's contentions that plea counsel was ineffective for failing to investigate the circumstances surrounding the drug - induced death.

I.

We discern the following facts and procedural history from the record.

On or about February 7, 2021, defendant distributed heroin laced with fentanyl to the victim in Lumberton Township. On February 8, 2021, the victim died from a fentanyl overdose. While unclear from the record, it appears that police

A-2079-24

orchestrated a controlled buy on the same day to engage defendant, who later confessed to police that she had distributed drugs to the victim.

On July 23, 2021, a grand jury returned a seven-count indictment, 2021-

07-0748-I, charging defendant with third-degree possession of a CDS, N.J.S.A. 2C:35-10(a)(1) (counts one, four, and five); third-degree possession of a CDS with intent to distribute, N.J.S.A. 2C:35-5(a)(1) and 2C:35-5(b)(13) (counts two and six); first-degree strict liability for drug-induced death, N.J.S.A. 2C:35-9(a) (count three); and third-degree conspiracy to distribute a CDS, N.J.S.A. 2C:5- 2a(1), N.J.S.A. 2C:35-5(a)(1), and N.J.S.A. 2C:35-5(b)(13) (count seven).

On September 30, 2021, a grand jury returned a separate five-count indictment, 2021-09-1107-I,1 charging defendant with third-degree possession of a CDS, N.J.S.A. 2C:35-10(a)(1) (counts one, two, three, and four), and third- degree possession of a CDS with intent to distribute, N.J.S.A. 2C:35-5(a)(1) and 2C:35-5(b)(5) (count five).

1 At the November 29, 2021, plea hearing, defendant informed her counsel and the court that indictment 2021-07-0748-I incorrectly listed the offense date as January 10, 2020. According to defendant's plea counsel, the correct date of the offense for the second indictment was February 8, 2021. The trial court found that while there were "ministerial issues with the dates" they were not "substantive enough to warrant" a new plea hearing. The trial court accepted defendant's guilty plea to strict liability for drug-induced death and possession with intent to distribute, finding that defendant entered that plea "knowingly, freely[,] and voluntarily."

A-2079-24

On November 8 and 29, 2021, defendant pled guilty to count three of indictment 2021-07-0748-I, first-degree strict liability for drug-induced death, and count five of indictment 2021-9-1107-I, third-degree possession of a CDS with intent to distribute. In exchange for the dismissal of the remaining counts of each indictment, the State recommended that defendant be sentenced to an eight-year prison term subject to the No Early Release Act (NERA), N.J.S.A. 2C:43-7.2(a), for the first-degree strict liability drug-induced death count, and a consecutive three-year prison term for the possession-with-intent-to-distribute count.

On January 21, 2022, defendant was sentenced in accordance with the plea agreement to eight years subject to NERA for first-degree strict liability for drug-induced death, and three years for third-degree possession of a CDS with intent to distribute. The trial court found aggravating factors three, the risk that the defendant will commit another offense, and nine, the need for deterring the defendant and others from violating the law, and ran defendant's sentences consecutively.

On March 29, 2023, following defendant's excessive sentencing appeal, we remanded the matter for the trial court to explain its reasons for imposing

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consecutive sentences. On June 5, 2023, the trial court modified defendant's sentences to run concurrently, not consecutively.

On November 6, 2023, defendant filed a self-represented petition for post-

conviction relief (PCR). In her petition, defendant alleged that her plea counsel was ineffective for: (1) failing to investigate and disprove that the CDS found in her possession after a controlled buy was in fact the same as the "3 wax fold" CDS found with the deceased victim, considering defendant's last contact with the victim was February 7, 2021 and he passed away the next day; (2) failing to investigate the conditions under which defendant waived her Miranda rights, considering she was under the influence of heroin at the time her rights were administered to her; (3) failing to present mitigating factors two, four, or twelve at sentencing, N.J.S.A. 2C:44-1(b) (2), (4), (12); and (4) failing to object to the fairness of the controlled buy with defendant, which occurred the same day the victim overdosed. Although PCR counsel was appointed, the record before us does not reflect that counsel submitted a brief in support of defendant's petition.

On February 13, 2025, the PCR court heard oral argument on defendant's petition. At oral argument, PCR counsel characterized defendant's requested relief as "a very narrow application for post-conviction relief," explaining that "the thrust of [defendant's] argument is that plea counsel failed to really press

A-2079-24

on [m]itigating [f]actor [f]our." Accordingly, the only issue that the PCR court considered at oral argument was whether sentencing counsel was ineffective in failing to present mitigating factor four—substantial grounds tending to excuse or justify the defendant's conduct, though failing to establish a defense. N.J.S.A. 2C:44-1(b)(4). In an oral decision, the court found that mitigating factor four would not be "particularly dispositive" of the sentence defendant received and denied defendant's petition without an evidentiary hearing. The PCR court did not consider any of the additional arguments raised in defendant's self - represented petition.

This appeal follows. Defendant raises the following contentions for our consideration:

POINT I

THIS COURT SHOULD REVERSE THE PCR COURT'S DECISION TO DENY THE DEFENDANT'S PETITION FOR POST-

CONVICTION RELIEF WITHOUT AN EVIDENTIARY HEARING BECAUSE THE DEFENDANT ESTABLISHED A PRIMA FACIE CLAIM THAT HER PLEA COUNSEL DID NOT INVESTIGATE THE CIRCUMSTANCES OF THE DRUG[-]INDUCED DEATH (NOT ADDRESSED BELOW).

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POINT II

THIS COURT SHOULD REVERSE THE PCR COURT'S DECISION TO DENY THE DEFENDANT'S REQUEST FOR AN EVIDENTIARY HEARING ON THE ISSUE OF WHETHER THE DEFENDANT'S ATTORNEY WAS INEFFECTIVE AT SENTENCING (PARTIALLY ADDRESSED BELOW).

II.

A.

We begin by addressing the legal principles governing this appeal.

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