State of New Jersey v. Datrell T. Williams
117 A.3d 1247
| N.J. Super. Ct. App. Div. | 2015Background
- In August 2011 defendant sold cocaine to an undercover officer on two occasions and, in a separate traffic stop, officers seized a large quantity of marijuana from a vehicle in which defendant was a passenger.
- Defendant was charged on the marijuana count (Indictment No. 12-04-0238), pleaded guilty in March 2013 and was sentenced on May 3, 2013 to two years of probation.
- Eleven days after sentencing, May 14, 2013, defendant was arrested and later indicted (Indictment No. 13-07-0671) for two third-degree counts of cocaine distribution based on the August 2011 undercover sales.
- The prosecutor delayed charging the undercover sales while an undercover investigation remained active and to preserve the undercover officer’s ability to continue operations; the investigation closed after the officer resigned in April 2013.
- The trial court dismissed the cocaine indictment with prejudice on grounds of "fundamental fairness," finding the prosecutor’s office should have coordinated internal files and that it was unfair to subject defendant to the subsequent prosecution.
- The Appellate Division reversed, finding double jeopardy and mandatory joinder did not bar prosecution and that dismissal on fundamental fairness was an abuse of discretion under these facts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether double jeopardy or mandatory joinder bars the cocaine indictment | State: charges are separate and not barred | Williams: offenses arose from same episode; plea resolved all matters | Held: Not barred by double jeopardy or mandatory joinder |
| Whether prosecution was fundamentally unfair given plea and internal office knowledge/delay | State: delay due to legitimate undercover objectives, not malicious | Williams: reasonable expectation plea resolved all pending matters; prosecution oppressive | Held: Fundamental fairness dismissal was improper; not a rare case warranting dismissal |
| Whether prosecutor's internal coordination obligations justify dismissal | State: no duty to canvass all files; reasonable practice to protect undercover ops | Williams: office should cross-reference files before accepting plea/sentencing | Held: Court declines to impose such duty; coordination concerns don't justify dismissal |
| Whether delay in charging constitutes harassment/oppression | State: delay reasonable and within statute of limitations; aimed at higher-degree charges | Williams: delay caused unfairness and surprised defendant post-sentencing | Held: Delay attributable to legitimate prosecutorial objectives; no harassment warranting dismissal |
Key Cases Cited
- Gregory, 66 N.J. 510 (adopted a mandatory joinder rule to prevent separate trials for offenses from same episode)
- Yoskowitz, 116 N.J. 679 (articulated four-part test for mandatory joinder and discussed fundamental fairness)
- Currie, 41 N.J. 531 (analyzed double jeopardy and reasonable expectations; fairness factors for multiple prosecutions)
- Tropea, 78 N.J. 309 (barred retrial on fundamental fairness grounds where State failed to produce essential proof)
- Tsoi, 217 N.J. Super. 290 (rejected fundamental fairness dismissal where multiple separate offenses were reasonably outside defendant’s expectations)