State of New Jersey v. Justin A. Lee
101 A.3d 622
| N.J. Super. Ct. App. Div. | 2014Background
- Lee sought PTI admission after being charged with two counts of aggravated assault against a police officer and resisting arrest; PTI director recommended admission but prosecutor denied.
- Trial court remanded for reconsideration and prosecutor amplified denial in writing; judge upheld denial after hearing arguments; Lee pled guilty to resisting arrest with probation recommendation.
- Lee invoked PTI Guideline 3(i) (presumption against PTI for violence) as inconsistent with N.J.S.A. 2C:43-12(e).
- Melee in Bloomfield with police response; disputes whether defendant felled nose deliberately or via police actions; eyewitness statements supported defendant’s version but did not confirm the nose was self-inflicted.
- PTI remains a prosecutorial function; Guideline 3(i) coexists with statute; no evidentiary hearing required; denial affirmed.
- Defendant’s factors considered but court found sufficient evidence to support denial under Guideline 3(i); no patent and gross abuse of discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| PTI Guideline 3(i) preempts by statute? | Lee argues Guideline 3(i) conflicts with PTI statute. | State contends guideline and statute align. | Guideline 3(i) not preempted; consistent with statute. |
| Standard of review when program director’s recommendation is overridden? | Lee seeks greater review beyond abuse of discretion. | State argues no change from enhanced deference. | Court keeps patent and gross abuse review standard. |
| Must court hold an evidentiary hearing on disputed PTI facts? | Lee requests an evidentiary mini-trial. | State opposes hearings as delaying prosecutorial discretion. | No evidentiary hearing required. |
| Was there a patent and gross abuse of discretion by prosecutor? | Lee alleges gross abuse. | State defends the discretionary denial. | No patent and gross abuse; denial affirmed. |
Key Cases Cited
- State v. Wallace, 146 N.J. 576 (1996) ( PTI discretionary framework; prosecutors weigh factors under statute and rule)
- State v. Bender, 80 N.J. 84 (1979) (highly deferential review of PTI decisions)
- State v. Negran, 178 N.J. 73 (2003) (limits on interference; check egregious injustice)
- State v. Brooks, 175 N.J. 215 (2002) (enhanced deference in PTI decisions)
- State v. Nwobu, 139 N.J. 236 (1995) (trial court credibility not resolved at PTI review)
- State v. Caliguiri, 158 N.J. 28 (1999) (PTI is discretionary; statutory guidance exists)
- State v. Leonardis, 72 N.J. 360 (1997) (abuse of discretion standard contexts)
- Watkins, 193 N.J. 507 (2008) (clear formulation of patent and gross abuse standard)