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, 2021Background
- 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)
