STATE OF NEW JERSEY VS. WILLIAM T. STELTZÂ (08-09-0207 AND 09-06-2098, CAMDEN COUNTY AND STATEWIDE)
A-3658-15T2
| N.J. Super. Ct. App. Div. | Nov 6, 2017Background
- William T. Steltz pleaded guilty (2009) to multiple drug and weapons counts in two indictments in exchange for a recommended aggregate sentence of 20 years (10 years parole ineligibility) and dismissal of other charges.
- At sentencing the judge announced an aggregate 19-year term with 8 years parole ineligibility; the written judgments initially matched 19 years/8 years.
- The Parole Board sought clarification; the sentencing judge amended the statements of reasons to reflect an aggregate of 19 years with 10 years parole ineligibility (Matlack correction of clerical errors doctrine invoked).
- Steltz repeatedly moved to correct the judgments and appealed; this Court previously affirmed the 19-year/10-year parole-ineligibility calculation and rejected Steltz’s jail-credit claim (prior appeal).
- Steltz later filed a PCR petition alleging ineffective assistance and incorrect jail-credit calculations; the trial court denied relief on parole-ineligibility (barred by R. 3:22-5) but amended the judgments to add 561 negotiated jail-credit days.
- On this appeal the Appellate Division: (1) held the parole-ineligibility and jail-credit claims were previously adjudicated and thus barred; (2) reversed the award of additional jail credits as inconsistent with prior holdings; and (3) remanded for resentencing on counts 4 and 6 because the imposed parole-ineligibility terms were illegal under the sentencing statute.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether parole-ineligibility term in judgments can be corrected to 10 yrs after judge’s amendment | State: Amendment reflected the judge’s intended aggregate parole-ineligibility (Matlack correction) | Steltz: Sentence actually imposed was 19 yrs/8 yrs; amendment improperly increased mandatory minimum | Prior appeal resolved the issue on the merits; R.3:22-5 bars relitigation—denial affirmed |
| Whether jail-credit calculation should include custody after prior sentencing (i.e., through Jan 7, 2010) | State: Opposed additional credits; argued prior rulings mean credits were correctly computed | Steltz: Counsel failed to secure negotiated jail credits through January 8, 2010; seeks PCR relief and amended JOCs | Claim previously litigated on appeal; award of additional credits reversed (defendant not entitled to credits for custody serving prior-imposed sentence) |
| Whether sentence structure (some counts concurrent, one consecutive) violated Rogers (partially-concurrent/consecutive prohibition) | State: The mixed concurrent/consecutive structure here violates Rogers and requires remand | Steltz: Sentence permitted because counts are across separate indictments and judge intended aggregate | Court rejected Rogers challenge—no Rogers violation because sentence variability problem not implicated; no remand on this ground |
| Whether parole-ineligibility terms on counts 4 & 6 are legal under N.J.S.A. 2C:35-5b(1) | State (raised on appeal): Three-year ineligibility terms on 14-year base sentences are less than one-third and thus unauthorized | Steltz: Did not expressly contest here; sought to preserve sentence math from earlier proceedings | Appellate Division agreed sentences on counts 4 & 6 were illegal under the statute and remanded for resentencing to impose legislatively-mandated parole-ineligibility periods |
Key Cases Cited
- State v. Warren, 115 N.J. 433 (1989) (trial court may consider State recommendation as a sentencing cap but defendant may argue for less)
- State v. Matlack, 49 N.J. 491 (1967) (court may correct clerical errors in judgments to reflect court’s intended sentence)
- State v. Hemphill, 391 N.J. Super. 67 (App. Div. 2007) (jail credits not allowed for time spent serving a previously imposed sentence)
- State v. C.H., 228 N.J. 111 (2017) (when multiple indictments produce consecutive sentences, view sentences together and apply jail credits to the front end of the aggregate sentence)
- State v. Rogers, 124 N.J. 113 (1991) (prohibits partially-concurrent/partially-consecutive sentence schemes that produce excessive variability)
- State v. Schubert, 212 N.J. 295 (2012) (courts may correct illegal sentences at any time because an illegal disposition is unauthorized by the Code)