State v. Michael Konecny (084880) (Monmouth County & Statewide)

CourtSupreme Court of New Jersey
DecidedApril 5, 2022
DocketA-21-20
StatusPublished

This text of State v. Michael Konecny (084880) (Monmouth County & Statewide) (State v. Michael Konecny (084880) (Monmouth County & Statewide)) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Michael Konecny (084880) (Monmouth County & Statewide), (N.J. 2022).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

State v. Michael A. Konecny (A-21-20) (084880)

Argued September 13, 2021 -- Decided April 5, 2022

PIERRE-LOUIS, J., writing for a unanimous Court.

In State v. Laurick, the Court held that prior uncounseled convictions for driving while intoxicated (DWI) cannot be used to enhance a custodial sentence for a second or subsequent DWI offense. 120 N.J. 1 (1990). In this case, the Court considers whether Laurick relief also prohibits prior uncounseled DWI convictions from serving as predicates to increase a custodial sentence for a later driving while suspended (DWS) conviction under N.J.S.A. 2C:40-26(b) (Section 26(b)).

Defendant Michael Konecny was convicted of DWI in 1986, and he pled guilty to another DWI offense in 1999. In 2014, defendant was arrested and charged with offenses including DWI and one count of refusal to take a breathalyzer test (Refusal). In 2016, defendant appeared in Middletown Township Municipal Court and pled guilty to the Refusal charge; his license was suspended for two years. During that period of suspension, defendant drove and was stopped by police on three separate occasions, resulting in three separate DWS charges under Section 26(b).

In April 2018, defendant pled guilty to all three Section 26(b) charges in Superior Court. The State, in turn, agreed to recommend that defendant be sentenced to 180 days on each count -- the statutory mandatory minimum period for a Section 26(b) conviction for a second or subsequent DWI or Refusal offense. Defendant then filed motions for post-conviction relief (PCR) regarding his 1999 DWI conviction as well as his 2016 Refusal conviction. Both petitions, made in the form of attorney certifications, alleged ineffective assistance of counsel as the basis for PCR.

In July 2018, defendant appeared before the Middletown Township Municipal Court in connection with his PCR motion for his 1999 offense. Although the prosecutor acknowledged that they were before the court on defendant’s PCR motion regarding ineffective assistance of counsel, the prosecutor made additional statements characterizing the motion as one seeking relief pursuant to Laurick. The court held that defendant’s 1999 counsel was constitutionally ineffective and that,

1 therefore, “the [1999] conviction should not be used as indicated in Laurick for enhancement of any penalties.” The court stated that it would enter an order to that effect and styled its decision as “grant[ing] PCR relief.”

Two days later, defendant appeared before the Union Beach Municipal Court on the PCR motion related to his 2016 Refusal conviction. Defense counsel represented that he had “prepared an updated order, because that is seeking PCR, this updated order [is] only seeking a Laurick order.” In response, the municipal court judge said, “this one I’ll sign, the other one I wouldn’t have,” and proceeded to sign the Laurick order.

Both municipal court orders specifically stated that the convictions were not to “be used to enhance any subsequent conviction” under either N.J.S.A. 39:3-40 or Section 26(b), pursuant to Laurick.

The Monmouth County Superior Court, however, found that Laurick relief was limited to sentencing for DWI convictions and could not be extended to Section 26(b) convictions. It sentenced defendant to 180 days’ imprisonment, and the Appellate Division affirmed. The Court granted certification. 244 N.J. 344 (2020).

HELD: Laurick relief and the principles underlying the prohibition against the use of uncounseled DWI convictions extend to the enhanced sentencing scheme in Section 26(b), and prior uncounseled convictions cannot be used as predicates to increase a loss of liberty for DWS. Furthermore, if a defendant obtains traditional PCR on a prior DWI or Refusal conviction and the State does not pursue a second prosecution, that vacated conviction cannot be used as a predicate in a Section 26(b) prosecution. In the present case, however, defendant was not entitled to Laurick relief in the first instance because he had counsel during his prior proceedings. Laurick is available only to defendants who were without counsel and not advised of their right to counsel during their DWI-related prosecutions.

1. The Court reviews in detail the DWI, Refusal, and DWS statutes. In 2009, the Legislature created two DWS-related offenses targeting individuals with repeated violations of alcohol-related traffic laws. Section 26(b), which is at issue in this appeal, created a fourth-degree offense for (1) operating a motor vehicle (2) during a period of license suspension, when (3) that suspension was imposed for a “second or subsequent violation” of DWI or Refusal. When those circumstances are met, a 180- day minimum sentence applies. See N.J.S.A. 2C:40-26(c). (pp. 14-18)

2. In considering whether Laurick relief can apply to Section 26(b) convictions, the Court first rejects the argument that the 180-day sentence prescribed by Section 26 is a mandatory minimum sentence distinct from the enhanced penalties imposed by the DWI statute for multiple convictions. Upon close review of the statutes, the 2 Court finds no principled distinction between the two sentencing schemes. And although the facts of Laurick dealt with DWI convictions, nothing in the opinion limited its right-to-counsel principles to DWI matters. If a defendant obtains Laurick relief on a prior DWI or Refusal conviction, fairness dictates that the conviction upon which relief was granted cannot be used to increase that defendant’s sentence for DWS to 180 days’ imprisonment. (pp. 18-19)

3. Here, however, defendant was not entitled to Laurick relief on either his 1999 or his 2016 conviction based on his ineffective assistance of counsel claims. The Laurick Court 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.” 120 N.J. at 16. Laurick created a special form of PCR that does not vacate the conviction, as in traditional PCR, but simply prevents the use of an uncounseled and unreliable DWI conviction to enhance a subsequent sentence. Id. at 4-5. But Laurick relief is available only to defendants whose DWI convictions were uncounseled. In the present case, defendant unquestionably had counsel during the prior proceedings at issue, and the municipal courts erred in granting defendant Laurick relief. The Court therefore affirms defendant’s sentence. (pp. 20-25)

4. The petition defendant originally filed for PCR alleging ineffective assistance of counsel was the appropriate motion here. Accordingly, defendant was required to abide by the general principles governing post-conviction relief and the five-year time-bar in the absence of excusable neglect. The Court explains how those principles operate in the context of defendant’s claims. (pp. 25-26)

5. Turning to the effect of vacating a conviction through PCR, the Court finds that if the State does not initiate a second prosecution or the matter is otherwise dismissed, the vacated conviction cannot then serve as a basis for charging a defendant with another offense. Thus, a conviction vacated through PCR cannot be used as a predicate for a Section 26(b) prosecution. (pp. 26-29)

6. The Court considers the language of Rule 7:10-2, which covers PCR in municipal court.

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

Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Nichols v. United States
511 U.S. 738 (Supreme Court, 1994)
State v. Hrycak
877 A.2d 1209 (Supreme Court of New Jersey, 2005)
State v. Fritz
519 A.2d 336 (Supreme Court of New Jersey, 1987)
State v. Laurick
575 A.2d 1340 (Supreme Court of New Jersey, 1990)
State v. Mitchell
601 A.2d 198 (Supreme Court of New Jersey, 1992)
Rodriguez v. ROSENBLATT
277 A.2d 216 (Supreme Court of New Jersey, 1971)
State v. Preciose
609 A.2d 1280 (Supreme Court of New Jersey, 1992)
State v. Ciancaglini
10 A.3d 870 (Supreme Court of New Jersey, 2011)
State v. Reinaldo Fuentes (070729)
85 A.3d 923 (Supreme Court of New Jersey, 2014)
State v. Sylvester
96 A.3d 256 (New Jersey Superior Court App Division, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Michael Konecny (084880) (Monmouth County & Statewide), Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-michael-konecny-084880-monmouth-county-statewide-nj-2022.