STATE OF NEW JERSEY VS. ERIC OBUGYEI (10-10-1875, BERGEN COUNTY AND STATEWIDE)

CourtNew Jersey Superior Court Appellate Division
DecidedJune 17, 2021
DocketA-1365-20
StatusUnpublished

This text of STATE OF NEW JERSEY VS. ERIC OBUGYEI (10-10-1875, BERGEN COUNTY AND STATEWIDE) (STATE OF NEW JERSEY VS. ERIC OBUGYEI (10-10-1875, BERGEN COUNTY AND STATEWIDE)) 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 VS. ERIC OBUGYEI (10-10-1875, BERGEN COUNTY AND STATEWIDE), (N.J. Ct. App. 2021).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-1365-20

STATE OF NEW JERSEY,

Plaintiff-Respondent,

v.

ERIC OBUGYEI, a/k/a ERIC B. OBUGYEI, and ERIC BOFAHO,

Defendant-Appellant. _________________________

Submitted June 7, 2021 – Decided June 17, 2021

Before Judges Rothstadt, Mayer and Susswein.

On appeal from the Superior Court of New Jersey, Law Division, Bergen County, Indictment No. 10-10-1875.

Joseph E. Krakora, Public Defender, attorney for appellant (Jennifer M. Blum, Assistant Deputy Public Defender, of counsel and on the brief).

Mark Musella, Bergen County Prosecutor, attorney for respondent (Deepa S.Y. Jacobs, Assistant Prosecutor, of counsel and on the brief).

PER CURIAM Defendant Eric Obugyei appeals from the Law Division's December 31,

2020 denial of his motion under Rule 3:21-10(b)(2) for release from prison due

to illness or infirmity. On appeal, he contends that the trial court erred by

concluding he could not seek release under the Rule until he completed his

mandatory period of parole ineligibility required by the No Early Release Act

(NERA), N.J.S.A. 2C:43-7.2 and, in any event, he did not meet the criteria for

medical release.

Defendant is currently incarcerated in State prison, serving a fourteen -

year NERA sentence that the trial court imposed in 2012 after defendant pled

guilty pursuant to a plea agreement to first-degree kidnapping. On October 10,

2020, defendant filed his motion for release and asserted that due to his medical

condition, atrial fibrillation (Afib), he was at risk of suffering a serious illness

if he contracted COVID-19 while in prison.

At the time he filed his motion, defendant was thirty-one years old. A

review of his medical records submitted as part of his motion for release reveals

he had an EKG on August 6, 2020, and the results came back normal. He also

took COVID-19 tests in May, July, and August 2020, and all results came back

negative. He underwent a physical exam on July 29, 2020, which yielded normal

results. He takes aspirin as part of his daily medication routine.

A-1365-20 2 While incarcerated, defendant obtained his G.E.D. and associate degree

from community college. He also received several certifications and completed

a number of programs.

In support of his motion, defendant also submitted two reports from

professionals who specialize in the effect of infectious diseases, like COVID-19

specifically, in the context of detention settings. One report was from Dr. Jaimie

Meyer, an assistant professor of medicine at the Yale School of Medicine and

assistant clinical professor of nursing at the Yale School of Nursing. She is

board certified in internal medicine, infectious diseases, and addiction medicine ,

and she has worked on infectious diseases in the context of detention settings

for over a decade. The other report was from Chris Beyrer, a professor of

epidemiology, international health, and medicine at the Johns Hopkins

Bloomberg School of Public Health. Neither report addressed any of defendant's

health conditions or any specific risk to him. Instead, the two experts discussed

in general terms the danger of the COVID-19 pandemic to prisoners.

Judge Keith Bachmann heard oral argument on December 10, 2020, before

he entered an order denying defendant's motion on December 31, 2020.1 In an

accompanying statement of reasons, Judge Bachmann explained that because

1 The transcript of the oral argument was not provided on this appeal. A-1365-20 3 defendant was sentenced under NERA, he was not eligible for parole until May

4, 2022, and that the medical records defendant submitted in support of his

motion did not contain an "opinion from any physician[] as to what . . .

defendant suffers from, much less that any malady would be exacerbated by his

incarceration," nor did they contain an expert opinion "that medical treatment

available outside of the prison system would avoid said exacerbation."

The judge then reviewed the contents of defendant's medical records and

concluded that while they revealed defendant had complained of various

ailments, "the results of the objective testing did not support his complaints."

Judge Bachmann also observed that even if defendant established that he

suffered from an illness and that treatment "to prevent further deterioration of

his health" was not available in prison, defendant would still not be eligible for

release under our holding in State v. Mendel, 212 N.J. Super. 110, 113-14 (App.

Div. 1986). Quoting our opinion in Mendel, the judge stated a "defendant [who]

is serving a parole ineligibility term . . . required by statute" is not eligible for

release under Rule 3:21-10(b) until "after completion" of that term.

Judge Bachmann continued by applying the Court's holding in State v.

Priester, 99 N.J. 123 (1984), which stated that "[t]he predicate for relief . . . is

proof of the serious nature of the defendant's illness and the deleterious effect

A-1365-20 4 of incarceration on the prisoner's health." He noted again that defendant had not

vaulted the medical threshold for consideration but, had such proof existed, it

would have led to a balancing of, as the judge stated, "the idea of releasing the

defendant against the need to deter a defendant who has committed a serious

crime." If defendant had met that criteria, the judge stated the "balance . . .

would rest in favor of continuing the defendant's incarceration." Finally, the

judge considered defendant's arguments that the Court Rules should be relaxed

under Rule 1:2-2 and that the denial of release violated defendant's federal and

state constitutional rights, concluding that a relaxation was not warranted and

none of defendant's rights had been violated. This appeal followed.

On appeal, defendant argues the following points:

POINT I

DEFENDANT'S MANDATORY MINIMUM UNDER NERA DOES NOT PREVENT A TEMPORARY CHANGE IN CUSTODY, DUE TO AN ILLNESS OR INFIRMITY.

POINT II

THE TRIAL COURT MISAPPLIED THE PREVAILING LAW AS IT RELATES TO THE FACTOR[S] UNDER STATE V. PRIESTER, REGARDING THE 'SERIOUS NATURE OF DEFENDANT'S MEDICAL CONDITION AND THE

A-1365-20 5 DELETERIOUS EFFECT OF INCARCERATION ON DEFENDANT'S HEALTH.'[2]

We are not persuaded by these contentions.

Rule 3:21-10(b)(2) provides: "[a] motion may be filed and an order may

be entered at any time . . . amending a custodial sentence to permit the release

of a defendant because of illness or infirmity of the defendant." "Courts apply

a balancing test to determine whether this 'extraordinary relief' should be

granted." In re Request to Modify Prison Sentences, 242 N.J. 357, 378 (2020)

(quoting Priester, 99 N.J. at 135).

Generally, to obtain such relief, an "inmate[] must [first] present evidence

of both an 'illness or infirmity'—a physical ailment or weakness—and the

increased risk of harm incarceration poses to that condition. A generalized fear

of contracting an illness is not enough." Id. at 379. Also, before the pandemic,

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Related

State v. Tumminello
358 A.2d 769 (Supreme Court of New Jersey, 1976)
Flagg v. Essex County Prosecutor
796 A.2d 182 (Supreme Court of New Jersey, 2002)
State v. Priester
491 A.2d 650 (Supreme Court of New Jersey, 1985)
State v. Mendel
514 A.2d 67 (New Jersey Superior Court App Division, 1986)
State v. Brown
894 A.2d 105 (New Jersey Superior Court App Division, 2006)
State v. Williams
204 A.3d 321 (New Jersey Superior Court App Division, 2019)

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STATE OF NEW JERSEY VS. ERIC OBUGYEI (10-10-1875, BERGEN COUNTY AND STATEWIDE), Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-new-jersey-vs-eric-obugyei-10-10-1875-bergen-county-and-njsuperctappdiv-2021.