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STATE OF NEW JERSEY VS. WILLIAM JENKINS, JR. (19-03-0275, BERGEN COUNTY AND STATEWIDE)
A-1328-19
| N.J. Super. Ct. App. Div. | Oct 27, 2021
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Background

  • June 25, 2018: defendant assaulted a victim in Bergen County; the victim later died. Defendant was arrested in New York on a parole-violation related matter.
  • New Jersey charged defendant June 27, 2018; he pleaded guilty in New York to the parole violation on July 31, 2018 and remained in NY custody.
  • Defendant submitted an Interstate Agreement on Detainers (IAD) disposition request on November 8, 2018, triggering a 180‑day deadline (expiration May 7, 2019). He was transferred to NJ on December 19, 2018 and indicted March 1, 2019.
  • In March 2019 the State sought a 90‑day extension under the IAD for outstanding discovery, lab results, and witness coordination; the trial court granted the extension on April 22, 2019, resetting the date to September 17, 2019.
  • Defendant pleaded guilty to amended Count One (second‑degree reckless manslaughter) as part of a plea agreement preserving his right to appeal the IAD extension; he was sentenced to 10 years with 85% parole ineligibility, concurrent to his NY sentence.
  • Defendant appealed, challenging (1) the IAD extension for lack of good cause and (2) the excessiveness of his sentence.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the trial court abused its discretion by granting a 90‑day IAD extension State: demonstrated good cause due to voluminous/outstanding discovery, pending lab work, and need to coordinate out‑of‑state witnesses Jenkins: State failed to show good cause; continuance violated the IAD and requires dismissal Court: Affirmed. Under totality of circumstances judge reasonably found good cause; no abuse of discretion
Whether the 10‑year sentence with 85% parole ineligibility was manifestly excessive State: sentence was part of plea agreement, within statutory range, supported by aggravating factors and no mitigators Jenkins: ten years with 85% bar is unduly punitive and should be reduced Court: Affirmed. Plea‑agreement sentence presumed reasonable; aggravating factors 3, 6, and 9 supported; sentence within statutory range

Key Cases Cited

  • State v. Buhl, 269 N.J. Super. 344 (App. Div. 1994) (IAD continuance reviewed for abuse of discretion)
  • State v. Perry, 430 N.J. Super. 419 (App. Div. 2013) (purpose of IAD is expeditious disposition and cooperative procedures)
  • Ghandi v. Cespedes, 390 N.J. Super. 193 (App. Div. 2007) (IAD does not define "good cause")
  • State v. Johnson, 188 N.J. Super. 416 (App. Div. 1982) (good‑cause inquiry requires totality of circumstances)
  • State v. Jones, 232 N.J. 308 (2018) (sentencing review standard; abuse of discretion)
  • State v. Fuentes, 217 N.J. 57 (2014) (plea‑agreement sentences presumptively reasonable)
  • State v. Bolvito, 217 N.J. 221 (2014) (standards for appellate review of sentencing)
  • State v. Roth, 95 N.J. 334 (1984) (framework for when appellate court may disturb a sentence)
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Case Details

Case Name: STATE OF NEW JERSEY VS. WILLIAM JENKINS, JR. (19-03-0275, BERGEN COUNTY AND STATEWIDE)
Court Name: New Jersey Superior Court Appellate Division
Date Published: Oct 27, 2021
Docket Number: A-1328-19
Court Abbreviation: N.J. Super. Ct. App. Div.