STATE OF NEW JERSEY v. ANTHONY B. HUGGINS (16-06-1175, 16-06-1271 AND 17-06-0982, OCEAN COUNTY AND STATEWIDE), A-4414-19

Background

Defendant Anthony Huggins entered guilty pleas in three separate indictments in 2017: CDS distribution (third degree) and loitering for obtaining CDS (disorderly persons) on April 17, and operating while suspended (DWI-related, fourth degree) on November 3.
The plea agreements resolved all three matters: the CDS pleas carried a recommended 364-day jail term concurrent to a six-month sentence; the aggregate resolution provided five years of special probation in drug court with a mandatory 180-day jail term (alternative four-year prison) for the motor vehicle offense.
At sentencing defendant received 82 days of jail credit applied to the CDS matters and 8 days applied to the motor vehicle charge; defendant later asserted he had been told he would receive 82–84 days credit toward the 180-day mandatory term for the motor vehicle offense.
Defendant filed a pro se PCR petition, later counseled, alleging ineffective assistance of plea counsel for (1) failing to prepare/meet, (2) misadvising about jail credits which induced the plea, and (3) failing to move to withdraw the plea; he requested an evidentiary hearing.
PCR Judge Ryan denied relief without an evidentiary hearing, concluding defendant failed to make a prima facie showing of deficient performance or prejudice under Strickland; credits pre-dating the motor-vehicle charge could not legally be applied to that charge, defendant made no claim of innocence, and any motion to withdraw would have been meritless under the Slater factors.
The Appellate Division affirmed, adopting the PCR court’s reasoning that the record shows the plea was voluntary, the jail-credit claim was legally impossible as to most days, there was no prejudice, and no entitlement to a hearing under Preciose.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plea counsel rendered ineffective assistance by misadvising about jail credits and inducing plea	Counsel was not deficient; most credits accrued before motor-vehicle charge and thus could not apply; defendant suffered no Strickland prejudice	Counsel told Huggins he would get 82–84 days credit toward the 180-day mandatory term, inducing his plea	Denied — no prima facie deficiency or prejudice; credits largely inapplicable to motor-vehicle charge; plea voluntary
Whether counsel failed to meet/prepare defendant for plea	Record shows defendant told the plea court he had sufficient time to consult counsel and signed plea knowingly	Counsel did not meet with or prepare him	Denied — plea colloquy and plea form undercut claim; no record support for lack of consultation
Whether counsel was ineffective for not moving to withdraw the guilty plea	Any motion would be meritless under Slater: no claim of innocence, weak reasons, and favorable plea bargain	Counsel should have filed motion to vacate based on jail-credit error	Denied — Slater factors weigh against withdrawal; counsel not ineffective for declining to file a meritless motion
Whether defendant was entitled to an evidentiary hearing on PCR claims	No prima facie showing of ineffective assistance; Preciose bars hearing absent such a showing	Defendant required a hearing to develop record on counsel’s promises and conduct	Denied — judge properly concluded no prima facie claim and thus no hearing required

Key Cases Cited

Strickland v. Washington, 466 U.S. 668 (1984) (two-pronged test for ineffective assistance of counsel)
State v. Fritz, 105 N.J. 42 (1987) (applying Strickland in New Jersey)
Padilla v. Kentucky, 559 U.S. 356 (2010) (prejudice inquiry in plea-context counsel advice cases)
State v. Maldon, 422 N.J. Super. 475 (App. Div. 2011) (plea decision rationality in Padilla context)
State v. Slater, 198 N.J. 145 (2009) (factors courts weigh on motions to withdraw guilty pleas)
State v. Preciose, 129 N.J. 451 (1992) (standard for entitlement to a PCR evidentiary hearing)
State v. O'Neal, 190 N.J. 601 (2007) (counsel not ineffective for not filing meritless motions)
State v. Warlock, 117 N.J. 596 (1990) (same)
State v. Cummings, 321 N.J. Super. 154 (App. Div. 1999) (bald/invocation-only assertions insufficient to show involuntary plea)