State of New Jersey v. Luis Rivas

CourtNew Jersey Superior Court Appellate Division
DecidedMarch 27, 2025
DocketA-1226-23
StatusUnpublished

This text of State of New Jersey v. Luis Rivas (State of New Jersey v. Luis Rivas) 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. Luis Rivas, (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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-1226-23

STATE OF NEW JERSEY,

Plaintiff-Respondent,

v.

LUIS RIVAS,

Defendant-Appellant. _______________________

Submitted March 18, 2025 – Decided March 27, 2025

Before Judges Gooden Brown and Vanek.

On appeal from the Superior Court of New Jersey, Law Division, Bergen County, Municipal Appeal No. 23-18.

The Tormey Law Firm, attorneys for appellant (Louis J. Keleher, on the brief).

Mark Musella, Bergen County Prosecutor, attorney for respondent (K. Charles Deutsch, Assistant Prosecutor, of counsel and on the brief).

PER CURIAM Defendant Luis Rivas appeals the trial court's order denying his motion to

dismiss the charge against him for operating a motor vehicle under the influence

of intoxicating liquor, N.J.S.A. 39:4-50(a). We affirm.

I.

We glean the salient facts from the record. At around 2:56 a.m. on

February 9, 2022, a Cresskill Police Officer observed defendant asleep in his

vehicle, parked on a residential street with the engine running and lights on.

Upon moving closer to defendant, the officer observed an open wine bottle in

the center console. After multiple attempts to wake defendant, he ultimately

rolled his window down for the responding officer. The officer detected an odor

of alcohol on defendant's breath and observed that defendant's eyes were

bloodshot and watery. Defendant failed field sobriety tests and was arrested for

operating a motor vehicle under the influence of intoxicating liquor (DWI),

N.J.S.A. 39:4-50(a), and for having an open alcoholic beverage container in the

vehicle, N.J.S.A. 39:4-51(b).

Defendant filed a motion to dismiss the DWI charge, contending the State

cannot establish his "operation" of the vehicle to establish his guilt. Based on

the undisputed material facts and prevailing law, the municipal court found that

the State had presented sufficient evidence that defendant had operated the

A-1226-23 2 vehicle in violation of N.J.S.A. 39:4-50(a) to proceed with its case and denied

the motion.

Defendant then entered a conditional guilty plea to both charges, reserving

his right to appeal. At the outset of the plea allocution, the parties stipulated

that defendant was intoxicated based on the officer's observations rather than

the Alcotest results. Defendant admitted he was sleeping in his vehicle while it

was running and that he consumed a standard-size bottle of wine, which

impacted his ability to operate the vehicle. Defendant also admitted he failed

the field sobriety tests, had bloodshot and watery eyes, smelled of alcohol, and

had an open bottle of wine in his car. The court accepted the guilty plea and

sentenced defendant to a three-month interlock with a license suspension until

its installation, twelve hours of Intoxicated Driver Resource Center education

courses, and payment of mandatory fines. The municipal court stayed

defendant's sentence pending appeal.

Defendant appealed the municipal court's denial of his motion to dismiss

the DWI charge to the Law Division. At the conclusion of oral argument, the

Law Division judge affirmed the municipal court's denial stating:

In the present case[,] I agree with the State and find that the record establishes defendant's guilt beyond a reasonable doubt for [DWI] under N.J.S.A. 39:4-50

A-1226-23 3 and that the [m]unicipal [c]ourt was correct to deny the motion to dismiss.

The New Jersey Appellate Division has confirmed that the State can prove operation through a variety of different methods including actual observation of the defendant in or out of the vehicle and the circumstances indicating that the defendant had been driving while intoxicated or by defendant's admission.

New Jersey case law also indicates that operation of a vehicle may be proven by any direct or circumstantial evidence as long as it is competent and meets the requisite standards of proof.

The broad definition of operation in the [DWI] Statute includes more than driving. In fact, [a] recent New Jersey case ruled on nearly analogous facts to this case . . . . There is no doubt that an intoxicated driver and sleeping defendant behind the wheel of a motor vehicle with the engine running is operating the vehicle within the meaning of N.J.S.A. 39:4-50(a). Even if the vehicle is not observed in motion, it is the possibility of motion that is relevant . . . .

In this case[,] no police officer witnessed the defendant driving the motor vehicle. However, law enforcement personally observed the defendant intoxicated and the keys in the ignition with the engine running. Since New Jersey courts have recently held that these two facts in conjunction meet the definition of operation under N.J.S.A. 39:4-50(a), I agree with the State and the findings of the [m]unicipal [c]ourt.

[(internal citations omitted).]

A-1226-23 4 Defendant appealed, raising the following arguments for our

consideration:

POINT I

THE SUPERIOR COURT COMMITTED REVERSIBLE ERROR BY HOLDING THAT THE STATE WAS ABLE TO PROVE INTENT TO OPERATE SOLELY WITH THE EVIDENCE THAT THE DEFENDANT WAS FOUND ASLEEP IN THE DRIVER'S SEAT WITH THE CAR RUNNING WHICH RESULTED IN EXTREME PREJUDICE TO THE DEFENDANT AND A MANIFEST INJUSTICE.

POINT II

THE MUNICIPAL COURT COMMITTED REVERSIBLE ERROR WHEN IT FAILED TO GRANT THE DEFENDANT'S MOTION TO DISMISS, AS THE STATE OF NEW JERSEY CANNOT PROVE THE DEFENDANT OPERATED A MOTOR VEHICLE IN VIOLATION OF N.J.S.A. 39:4-50.

Our analysis of defendant's arguments follows.

II.

Prevailing law informs our review, recognizing that on appeal of a Law

Division order entered after its de novo review of an appeal from a municipal

court determination, we "consider only the action of the Law Division and not

that of the municipal court." State v. Oliveri, 336 N.J. Super. 244, 251 (App.

Div. 2001) (citing State v. Joas, 34 N.J. 179, 184 (1961)).

A-1226-23 5 In reviewing the Law Division's decision on a municipal appeal, we must

focus on "whether there is 'sufficient credible evidence . . . in the record' to

support the trial court's findings." State v. Robertson, 228 N.J. 138, 148 (2017)

(quoting State v. Johnson, 42 N.J. 146, 162 (1964)). "A trial court's

interpretation of the law and the legal consequences that flow from established

facts are not entitled to any special deference." Rowe v. Bell & Gossett Co.,

239 N.J. 531, 552 (2019) (alteration in original) (quoting Manalapan Realty,

L.P. v. Twp. Comm. of Manalapan, 140 N.J. 366, 378 (1995)).

Having reviewed defendant's contentions in light of the record, we affirm

based on prevailing law. There was sufficient evidence in the record of

defendant's operation of the vehicle to withstand dismissal of the charge based

on our jurisprudence, including State v. Thompson, 462 N.J. Super. 370, 374

(App. Div. 2020), where we addressed "whether an intoxicated individual,

seated behind the wheel of a vehicle with its engine running, is in violation of

N.J.S.A. 39:4-50(a)." After police smelled the "strong odor of [an] alcoholic

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Related

State v. Oliveri
764 A.2d 489 (New Jersey Superior Court App Division, 2001)
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. Daly
313 A.2d 194 (Supreme Court of New Jersey, 1973)
State v. Joas
168 A.2d 27 (Supreme Court of New Jersey, 1961)
State v. Scott Robertson(075326)
155 A.3d 571 (Supreme Court of New Jersey, 2017)

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State of New Jersey v. Luis Rivas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-new-jersey-v-luis-rivas-njsuperctappdiv-2025.