State of New Jersey v. Rafiik A. Hester

CourtNew Jersey Superior Court Appellate Division
DecidedFebruary 13, 2026
DocketA-1804-24
StatusUnpublished

This text of State of New Jersey v. Rafiik A. Hester (State of New Jersey v. Rafiik A. Hester) 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. Rafiik A. Hester, (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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-1804-24

STATE OF NEW JERSEY,

Plaintiff-Respondent,

v.

RAFIIK A. HESTER,

Defendant-Appellant.

Submitted December 15, 2025 – Decided February 13, 2026

Before Judges Natali and Bergman.

On appeal from the Superior Court of New Jersey, Law Division, Monmouth County, Municipal Appeal No. 24-0018.

Anthony L. Cherry, Jr., attorney for appellant.

Raymond S. Santiago, Monmouth County Prosecutor, attorney for respondent (Michael Cricchi, Assistant Prosecutor, of counsel and on the brief).

PER CURIAM Defendant Rafiik A. Hester appeals from a Law Division order upholding

convictions in the Howell Township Municipal Court for obstruction and

resisting arrest pursuant to N.J.S.A. 2C:29-1A and 2C:29-2A(1). Defendant

challenges the validity of his waiver of his Sixth Amendment right to counsel,

contending the trial court erred in finding his waiver was knowing, intelligent,

and voluntary. After our review of the record and pertinent legal principles, we

affirm.

I.

On January 5, 2024, a resident of an apartment complex in Howell

Township, reported defendant—a guest in her home—was causing a disturbance

and refused to leave. Following a second call indicating defendant had moved

to his car outside, Corporal Ryan Hurley of the Howell Township Police

Department responded and found defendant in his motor vehicle. After Hurley’s

attempts at conversation and requests for identification were rebuffed, Hurley

ordered defendant out of the vehicle. Defendant refused, resulting in Hurley

and Officer Joseph McGovern forcibly removing and arresting defendant.

Defendant was charged with obstruction and resisting arrest.

On January 12, 2024, defendant appeared self-represented in municipal

court, checked a waiver box on a form indicating he was waiving his right to

A-1804-24 2 counsel, and appeared self-represented for subsequent proceedings on February

2, March 1, April 4, May 8, and June 12, 2024. He was convicted on both

charges and sentenced to ten days in jail, a $500 fine, and additional fees.

Defendant appealed to the Law Division on July 1, 2024. At the de novo

trial on November 12, 2024, he appeared with counsel. The conviction was

affirmed in a December 9, 2024 written opinion.

Defendant raises the following single point on appeal:

POINT ONE

THE MUNICIPAL COURT FAILED TO ESTABLISH THAT APPELLANT KNOWINGLY, INTELLIGENTLY, AND VOLUNTARILY WAIVED HIS SIXTH AMENDMENT RIGHT TO COUNSEL.

Specifically, defendant asserts the trial court failed to conduct an adequate

inquiry to ensure he understood: (1) the charges and consequences, (2) statutory

defenses and mitigating circumstances, (3) the range of potential punishments,

(4) the availability of counsel if indigent, and (5) the risks and disadvantages of

self-representation. He contends that absent an affirmative, on-the-record

showing of understanding and waiver, his conviction should be reversed. We

are unpersuaded.

A-1804-24 3 II.

A trial court's determination that a defendant knowingly and voluntarily

waived his right to representation is reviewed for abuse of discretion. State v.

DuBois, 189 N.J. 454, 475 (2007). "A court abuses its discretion when its

'decision is made without a rational explanation, inexplicably departed from

established policies, or rested on an impermissible basis.'" State v. Chavies, 247

N.J. 245, 257 (2021) (quoting State v. R.Y., 242 N.J. 48, 65 (2020) (internal

citations omitted)).

The Sixth Amendment to the United States Constitution and Article I,

Paragraph 10 of the New Jersey Constitution grant the criminally accused "both

the right to counsel and the right to proceed to trial without counsel." DuBois,

189 N.J. at 465. Criminal defendants possess "the right to proceed without

counsel when they voluntarily and intelligently elect to do so." Ibid. (citing

Faretta v. California, 422 U.S. 806, 818 (1975)).

A trial court must determine whether a defendant's waiver of his right to

counsel "is indeed knowing, voluntary, and intelligent after a searching inquiry

that involves advising the defendant of the risks and pitfalls of self-

representation." State v. Rose, 458 N.J. Super. 610, 627 (App. Div. 2019) (citing

DuBois, 189 N.J. at 468-69; State v. Figueroa, 186 N.J. 589, 593 (2006); State

A-1804-24 4 v. Reddish, 181 N.J. 553, 593-95 (2004); State v. Crisafi, 128 N.J. 499, 510-12

(1992)).

To ensure a defendant's waiver is knowing and intelligent, trial courts

must conduct an inquiry to inform defendants seeking to proceed self-

represented about:

(1) the nature of the charges, statutory defenses, and possible range of punishment; (2) the technical problems associated with self-representation and the risks if the defense is unsuccessful; (3) the necessity that [the] defendant comply with the rules of criminal procedure and the rules of evidence; (4) the fact that the lack of knowledge of the law may impair [the] defendant's ability to defend himself or herself; (5) the impact that the dual role of counsel and defendant may have; (6) the reality that it would be unwise not to accept the assistance of counsel; (7) the need for an open-ended discussion so that the defendant may express an understanding in his or her own words; (8) the fact that, if [the] defendant proceeds pro se, he or she will be unable to assert an ineffective assistance of counsel claim; and (9) the ramifications that self- representation will have on the right to remain silent and the privilege against self-incrimination.

[State v. Outland, 245 N.J. 494, 506 (2021) (quoting DuBois, 189 N.J. at 468-69).]

"In the exceptional case, if the record indicates that the defendant actually

understood the risks of proceeding [self-represented], a waiver may suffice."

Crisafi, 128 N.J. at 513. This is a limited exception that applies only in rare

A-1804-24 5 cases. Ibid. In Crisafi, the Court held that although the trial court failed to

advise the defendant of the risks proceeding on a self-represented basis, he was

"a court-wise criminal who fully appreciated the risks of proceeding without

counsel, and that he decided to proceed [self-represented] with his eyes open."

Ibid. "The determination of whether there has been an intelligent waiver of right

to counsel must depend, in each case, upon the particular facts and

circumstances surrounding that case, including the background, experience, and

conduct of the accused." Johnson v. Zerbst, 304 U.S. 458, 464 (1938).

Our review of the record convinces us the trial court did not err in its

determination defendant was aware of and knowingly waived his right to legal

counsel. Before trial, the following colloquy took place between the municipal

judge and defendant:

MR. HESTER: [I]s this – for the record, is this trial by [j]ury?

THE COURT: No sir, this is not the Supreme Court –

MR. HESTER: So, this is not a trial –

THE COURT: It is a trial.

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Related

Johnson v. Zerbst
304 U.S. 458 (Supreme Court, 1938)
Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Faretta v. California
422 U.S. 806 (Supreme Court, 1975)
Cipala v. Lincoln Technical Institute
843 A.2d 1069 (Supreme Court of New Jersey, 2004)
State v. Reddish
859 A.2d 1173 (Supreme Court of New Jersey, 2004)
State v. Crisafi
608 A.2d 317 (Supreme Court of New Jersey, 1992)
State v. Figueroa
897 A.2d 1050 (Supreme Court of New Jersey, 2006)
State v. DuBois
916 A.2d 450 (Supreme Court of New Jersey, 2007)
State v. Rose
206 A.3d 995 (New Jersey Superior Court App Division, 2019)

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State of New Jersey v. Rafiik A. Hester, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-new-jersey-v-rafiik-a-hester-njsuperctappdiv-2026.