State of New Jersey v. Lindsey M. Krakowiak

CourtNew Jersey Superior Court Appellate Division
DecidedMay 16, 2025
DocketA-3997-23
StatusUnpublished

This text of State of New Jersey v. Lindsey M. Krakowiak (State of New Jersey v. Lindsey M. Krakowiak) 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. Lindsey M. Krakowiak, (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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-3997-23

STATE OF NEW JERSEY,

Plaintiff-Respondent,

v.

LINDSEY M. KRAKOWIAK,

Defendant-Appellant.

Argued May 5, 2025 – Decided May 16, 2025

Before Judges Sabatino, Berdote Byrne and Jablonski.

On appeal from the Superior Court of New Jersey, Law Division, Sussex County, Municipal Appeal No. 09-05- 24.

Keith G. Napolitano Jr. argued the cause for appellant (Levow DWI Law, PC, attorneys; Evan M. Levow, of counsel and on the brief; Keith G. Napolitano Jr., on the brief).

Jonathan E. McMeen, Special Deputy Attorney General/Acting Assistant Prosecutor, argued the cause for respondent (Sahil K. Kabse, Acting Sussex County Prosecutor, attorney; Jonathan E. McMeen, of counsel and on the brief). PER CURIAM

Defendant Lindsey M. Krakowiak, who pled guilty in 2014 to driving

while intoxicated ("DWI"), appeals the Law Division's 2024 denial of her

petition for post-conviction relief ("PCR"). She claims she was not properly

advised in the 2014 proceeding of the enhanced penalties for a future DWI

conviction. We affirm.

In December 2013, defendant was charged with a DWI, N.J.S.A. 39:4-50.

Defendant was represented by counsel and entered into a plea agreement with

the State. After pleading guilty, she was sentenced to a two-year license

revocation, forty-eight hours in the Intoxicated Driver Resource Center, thirty

days of community service, and assessments and miscellaneous fees. She was

also required to install an ignition interlock device for one year. No appeal was

filed, and no PCR proceedings were brought until the present matter.

More than a decade after her conviction, in February 2024, defendant

brought a PCR petition asserting that she was not advised by counsel nor orally

by the court of the enhanced penalties for any subsequent DWI violations at the

time of her conviction, as required under N.J.S.A. 39:4-50(c). She therefore

sought not to be exposed to any enhanced penalties for a subsequent DWI.

A-3997-23 2 In April 2024, the PCR application was heard in the municipal court. The

municipal court noted that the judge who initially heard the matter in 2014 did

not orally advise defendant of the enhanced penalties upon her conviction, but

also noted that defendant had signed a written document in which she

acknowledged receiving this necessary information.

In May 2024, the municipal court denied the PCR petition, explaining that

defendant, in addition to receiving written notice, "was represented by

competent counsel and arraigned . . . at which point she was advised of her

constitutional rights and the penalties associated with a DWI."

Subsequently in May 2024, defendant appealed the municipal court's PCR

ruling to the Law Division.

In August 2024, the Law Division judge denied the municipal appeal. The

court found that the PCR application was procedurally barred under the five-

year limit of Rule 7:10-2(b)(2) and explained "[t]here's nothing under [State

v. ]Laurick[, 120 N.J. 1 (1990)] [1] or [State v. ]Petrello[, 251 N.J. Super. 476,

1 Laurick, 120 N.J. at 13, held that "an uncounseled conviction without waiver of the right to counsel is invalid for the purpose of increasing a defendant's loss of liberty. In the context of repeat DWI offenses, this means that the enhanced administrative penalties and fines may constitutionally be imposed but that in the case of repeat DWI convictions based on uncounseled prior convictions, the

A-3997-23 3 479 (App. Div. 1991)][2] that would have entitled [defendant] to an extension."

The court also noted that there is "nothing in our Constitution that entitles a

defendant to any constitutional right involving a written or oral notice of

enhanced potential sentences in the future, and therefore, there is no due process

requirement for prior notice for a future offense." The court observed that

"Petrello is binding on the [c]ourt [and] that enhanced penalties are appropriate

going forward, whether or not the defendant had previously been advised orally

or in writing of the penalties for a subsequent violation."

This appeal followed. On appeal, defendant raises the following point for

our consideration:

POINT ONE

THE HOLDING IN STATE V. PETRELLO MUST BE OVERTURNED AS IT CLEARLY CONFLICTS WITH THE STATUTORY LANGUAGE OF N.J.S.A. 39:4-50(c).

Having considered this argument in light of the record and the applicable

law, we affirm the PCR denial for two main reasons. First, defendant's claim is

time-barred. Second, even if we were to find cause to relax the time bar,

actual period of incarceration imposed may not exceed that for any counseled DWI convictions." 2 We will discuss Petrello in detail below. A-3997-23 4 Petrello, 251 N.J. Super. at 479, is binding precedent that substantively

precludes defendant's claim.

A single statutory provision frames our discussion. N.J.S.A. 39:4-50(c)

provides, in part, that:

The court shall inform the person convicted that if the person is convicted of personally operating a motor vehicle during the period of license suspension imposed pursuant to subsection (a) of this section, the person shall, upon conviction, be subject to the penalties established in R.S.39:3-40. The person convicted shall be informed orally and in writing. A person shall be required to acknowledge receipt of that written notice in writing. Failure to receive a written notice or failure to acknowledge in writing the receipt of a written notice shall not be a defense to a subsequent charge of a violation of R.S.39:3-40 . . . Upon conviction of a violation of this section, the court shall notify the person convicted, orally and in writing, of the penalties for a second, third or subsequent violation of this section. A person shall be required to acknowledge receipt of that written notice in writing. Failure to receive a written notice or failure to acknowledge in writing the receipt of a written notice shall not be a defense to a subsequent charge of a violation of this section.

[(Emphasis added).]

In Petrello, 251 N.J. Super. at 476, we ruled that it was "abundantly clear"

that "the enhanced penalties of N.J.S.A. 39:4-50 must be imposed at sentencing

on entry of a second drunk-driving conviction, regardless of . . . whether or not

A-3997-23 5 [the] defendant had previously been advised orally or in writing of the penalties

for a subsequent violation." Id. at 479 (emphasis added).

We found the statute supported this reading, as follows:

The basis for this position is the language in the statute providing that the failure of the court to provide defendant with written notice is not a defense to a subsequent charge, coupled with silence of the statute as to the effect of a failure to so notify the defendant orally. . . . [There is] obvious legislative intent to provide enhanced penalties for each subsequent conviction of the statute. [Reading a strict oral notice requirement in the statute would illogically] reward the defendant who intentionally or negligently fails to appear in court and subsequently violates the statute because he could not then be sentenced as a subsequent offender.

[Id. at 478.]

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Bringhurst
951 A.2d 238 (New Jersey Superior Court App Division, 2008)
State v. Laurick
575 A.2d 1340 (Supreme Court of New Jersey, 1990)
State v. Weil
22 A.3d 983 (New Jersey Superior Court App Division, 2011)
State v. Petrello
598 A.2d 927 (New Jersey Superior Court App Division, 1991)
State v. Nicolai
671 A.2d 611 (New Jersey Superior Court App Division, 1996)
State v. Zeikel
30 A.3d 339 (New Jersey Superior Court App Division, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
State of New Jersey v. Lindsey M. Krakowiak, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-new-jersey-v-lindsey-m-krakowiak-njsuperctappdiv-2025.