State of New Jersey v. Ludovico Arico

CourtNew Jersey Superior Court Appellate Division
DecidedMay 21, 2025
DocketA-2740-23
StatusUnpublished

This text of State of New Jersey v. Ludovico Arico (State of New Jersey v. Ludovico Arico) 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. Ludovico Arico, (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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-2740-23

STATE OF NEW JERSEY,

Plaintiff-Respondent,

v.

LUDOVICO ARICO,

Defendant-Appellant. _________________________

Argued March 11, 2025 – Decided May 21, 2025

Before Judges Sumners and Perez Friscia.

On appeal from the Superior Court of New Jersey, Law Division, Essex County, Municipal Appeal No. 2023- 022.

Marco A. Laracca argued the cause for appellant (Bio & Laracca, PC, attorneys; Marco A. Laracca, of counsel and on the briefs).

Stephen A. Pogany, Assistant Prosecutor, argued the cause for respondent (Theodore N. Stephens, II, Essex County Prosecutor, attorney; Stephen A. Pogany, on the brief).

PER CURIAM Defendant Ludovico Arico appeals his conviction for driving while

intoxicated (DWI), N.J.S.A. 39:4-50, based on observation following a trial de

novo in the Law Division. After reviewing the record and the parties' arguments

in light of the applicable legal standards, we affirm substantially for the reasons

stated by Judge Arthur J. Batista in his thoughtful decision.

I

The pertinent evidence was set forth in Judge Batista's decision and need

not be repeated in detail here. A summary will suffice.

Shortly before 4 a.m. on April 22, 2023, Cedar Grove Police Officer

Nyron Watson was dispatched to a reported car crash in the area of Stevens

Avenue and Route 22. Officer Watson responded immediately and observed a

telephone pole that was snapped in half and leaning over, held up only by wires.

The officer also observed a "trail of fluids and tire marks leading north down

Stevens [Avenue]," with fluid crossing over the roadway's yellow lines into the

oncoming lane of traffic and leading to a white pickup truck nearby on Lopez

Road with its hazard lights on and smoke wafting from its engine. Defendant

was in the driver's seat of the vehicle with no passengers.

Officer Watson's engagement with defendant was recorded on his body-

worn camera. As revealed in the recording played at trial, as defendant exited

A-2740-23 2 his truck he could be heard stating: "Fucking deer. It just crossed the street."

Officer Watson detected the "strong odor" of an "alcoholic beverage emanating

from [defendant's] breath." When Officer Watson asked defendant if he had

been drinking, defendant first said he had a "couple glasses of wine" at his

friend's restaurant in Newark. However, moments later, defendant stated he,

"honest[ly]," had "a couple of beers."

Officer Watson then proceeded to administer field sobriety tests on

defendant, including the horizontal gaze nystagmus (HGN), the walk-and-turn,

and the one-leg stand. Officer Watson recalled that there was no indication

defendant suffered any head trauma from the accident making the testing

ineffective. As for the HGN test, Officer Watson testified it revealed two clues

for nystagmus in each eye. For the walk-and-turn, he said defendant "stepped

off the line," "started before I instructed him to," and "turned incorrectly." For

the one-leg stand, defendant was instructed to raise his right leg, keep it raised,

and count "one 1,000, two 1,000, so on and so forth." However, defendant

"[f]ailed to keep his balance," counting only to two before putting his foot down.

Defendant also "started to sway a little bit, which is another indicator" of

intoxication. After lifting his foot back up, defendant counted:

One 1,000, three 1,000, four 1,000, five 1,000, six 1,000, seven 1,000, eight nine-thousand, nine nine-

A-2740-23 3 thousand, eight nine-thousand, 10 10-thousand, 11- thousand, 12-thousand, 13-thousand, 14-thousand, 15- thousand, 16-thousand, 17-thousand, 18-thousand, 19- thousand.

Based on the totality of circumstances, Officer Watson arrested defendant

for DWI and transported him to police headquarters. After defendant was

Mirandized,1 he again changed his story about his drinking that night, saying

"he had two Coronas and one shot of Hennessey [cognac]."

Sergeant Joseph Ligas, who was also at the arrest scene, conducted an

Alcotest on defendant. Sergeant Ligas used his body-worn camera to record

defendant's interaction with Officer Watson, and the recording was admitted into

evidence. Sergeant Ligas testified defendant gave two valid samples, which

calculated a .07 blood alcohol concentration (BAC).2 Sergeant Ligas also

recounted his observation of defendant, stating he recognized a "distinct odor of

alcohol coming off" defendant, and that his "[e]yes were bloodshot." He also

testified that, based on his training and experience, defendant "absolutely"

appeared to be intoxicated.

1 Miranda v. Arizona, 384 U.S. 436 (1966). 2 A BAC of .08 or higher constitutes a per se DWI violation under N.J.S.A. 39:4-50. A-2740-23 4 Defendant was charged with careless driving, N.J.S.A. 39:4-97; leaving

the scene of an accident, N.J.S.A. 39:4-129; failure to report an accident with

property damage, N.J.S.A. 39:4-129; and driving while intoxicated (DWI),

N.J.S.A. 39:4-50(a). Trial was held in Cedar Grove Municipal Court over three

days in September and November 2023. Defendant was found guilty of DWI,

leaving the scene, and failure to report an accident, but not guilty of careless

driving.

Defendant filed for trial de novo in the Law Division, appealing only the

DWI and leaving the scene convictions. After briefing and argument, Judge

Batista issued an order upholding defendant's convictions and imposing the

same sentence as the municipal court.

The judge explained his findings in a thirty-eight-page written decision.

Recognizing defendant's DWI charge was based on observation, the judge noted

the "history and propriety of observation cases in New Jersey is well grounded,"

and the "general proposition that an individual cannot be convicted solely based

upon observation and opinion testimony is erroneous."

The judge was unpersuaded by the opinion of defendant's expert witness

challenging defendant's field sobriety test. The judge determined there was no

evidence "indicating that [] [defendant] suffered any type of injury that would

A-2740-23 5 have potentially affected his performance on the field sobriety tests," thus, there

was "no issue with [defendant] having been made to perform the field sobriety

tests." Yet the judge, relying upon State v. Doriguzzi, 334 N.J. Super. 530, 538-

39 (App. Div. 2000), did "not consider[] the HGN results . . . as evidence of

guilt" because the "test currently lacks sufficient general accepted indicia of

scientific reliability to be admitted as proof of intoxication at trial."

The judge, however, found defendant's performance of the other field

sobriety tests—as depicted in the body-worn camara recordings—supported

defendant's DWI conviction. As for the walk-and-turn test, the judge found

defendant "exhibited three markers of failure" –– (1) during the instructional

phase he could not keep his balance; (2) he started too soon; and (3) during the

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Related

Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Midler v. Heinowitz
89 A.2d 458 (Supreme Court of New Jersey, 1952)
State v. Doriguzzi
760 A.2d 336 (New Jersey Superior Court App Division, 2000)
State v. Locurto
724 A.2d 234 (Supreme Court of New Jersey, 1999)
State v. Brown
573 A.2d 886 (Supreme Court of New Jersey, 1990)
Manalapan Realty v. Township Committee of the Township of Manalapan
658 A.2d 1230 (Supreme Court of New Jersey, 1995)
State v. Johnson
199 A.2d 809 (Supreme Court of New Jersey, 1964)
State v. Elders
927 A.2d 1250 (Supreme Court of New Jersey, 2007)

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State of New Jersey v. Ludovico Arico, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-new-jersey-v-ludovico-arico-njsuperctappdiv-2025.