STATE OF NEW JERSEY VS. JESSE CHAMBERSÂ (09-02-0329, 13-01-0059 AND 13-03-0340, MIDDLESEX COUNTY AND STATEWIDE), A-2870-14T3

Background

Defendant Jesse Chambers pleaded guilty in 2009 to a CDS offense and was placed on Drug Court special probation; the 2009 plea included a nine-year alternate sentence with 54 months parole ineligibility if he failed Drug Court.
In 2013 Chambers pleaded guilty to additional CDS-related charges and the State recommended continued Drug Court participation; the 2013 plea carried a three-year alternate sentence to run consecutive to the 2009 alternate sentence, producing an aggregate 12-year exposure with 54 months parole ineligibility if probation was revoked.
In July 2014 Chambers was charged with four violations of probation (VOP): positive drug tests (2011, 2012, 2014), new criminal charges that formed the basis of the 2013 plea, noncompliance/discharge from treatment programs, and failure to pay court-imposed fines.
At the August 28, 2014 VOP hearing the judge denied requests to exclude certain lab reports and to adjourn, elicited colloquy from Chambers in which he admitted some conduct, and stated she accepted his guilty pleas based on his statements and her observation that he was not impaired.
The judge found VOPs by a preponderance of the evidence and immediately imposed the aggregate alternate sentence of 12 years with 54 months parole ineligibility. Chambers appealed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the VOP court complied with Rule 3:9-2 when accepting Chambers's guilty pleas	State relied on Chambers’s on-record statements and lab reports to establish factual basis and voluntariness	Chambers argued the court failed to inquire into voluntariness, understanding of consequences, coercion, and drug impairment as required by Rule 3:9-2	Vacated VOP convictions and remanded: judge failed to satisfy Rule 3:9-2 requirements when accepting guilty pleas
Whether reliance on uncertified lab reports and pleadings violated confrontation/due process	State maintained the lab reports and record statements supported the VOP findings	Chambers argued confrontation and due process were violated by use of uncertified lab reports and lack of live testimony	Court did not reach merits because plea acceptance deficient; other issues reserved for remand
Whether denial of adjournment and procedural rulings violated Chambers’s rights to contest VOPs	State argued proceedings were procedurally proper and prompt adjudication appropriate	Chambers argued denial prevented adequate preparation and violated due process	Not addressed on merits due to remand for proper plea acceptance
Whether sentencing and revocation based on new charges, missed payments, or plea voluntariness were improper	State relied on plea agreements and factual findings to justify revocation and sentence	Chambers challenged plea voluntariness, plea-agreement protections, double jeopardy, and fairness of revocation for missed payments while incarcerated	Not reached; disposition vacated and remanded for new VOP hearing due to defective plea acceptance

Key Cases Cited

State v. Locurto, 157 N.J. 463 (1999) (standard of review for factual findings in VOPs and deference to trial judge)
State v. Campfield, 213 N.J. 218 (2013) (requirements for plea colloquy and inquiry into factual basis and voluntariness)
State v. Johnson, 42 N.J. 146 (1964) (preponderance standard for VOP findings)
State v. Elders, 192 N.J. 224 (2007) (deference to trial judge’s opportunity to observe witnesses)
State v. Lavoy, 259 N.J. Super. 594 (App. Div. 1992) (Rule 3:9-2 plea requirements apply to VOP pleas)