STATE OF NEW JERSEY VS. MARK EL (25-19, ATLANTIC COUNTY AND STATEWIDE), A-4480-19

On Nov. 13, 2016, Sgt. Thomas Rocco stopped Mark El's vehicle for dark tinted windows; a records check and driving abstract (S-1) showed El's New Jersey driving privileges were suspended.
El produced no NJ driver’s license and asserted a "Moorish American" "right to travel," denying a license requirement.
Municipal court trial took place Dec. 17, 2019; El proceeded pro se, was convicted of driving while suspended (N.J.S.A. 39:3-40), no license (N.J.S.A. 39:3-29A), and unlawful tint (N.J.S.A. 39:3-74), and sentenced.
El appealed to the Law Division for a de novo trial (June 30, 2020), represented there by a public defender, and argued the municipal judge was biased and that he lacked notice/discovery.
The Law Division reviewed the record, credited the officer’s testimony and S-1, rejected the bias and discovery/notice claims, and affirmed the municipal convictions and sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Judicial bias / recusal	Municipal judge’s familiarity with defendant did not show disqualifying bias	Judge’s comments about being "very familiar" and defendant's frequent appearances show prejudice requiring remand	No bias; comments were permissible and insufficient to require recusal
Sufficiency of evidence for convictions	Officer testimony + unobjected driving abstract proved suspension and stop for illegal tint	Defendant admitted no license and asserted constitutional "right to travel," denying licensing requirement	Evidence sufficient; admissions and S-1 supported convictions
Notice / discovery / fair trial	Defendant was informed of trial date previously; traffic tickets constituted available discovery	Defendant said he lacked notice and discovery and thus was denied a fair trial	Claims unsupported; defendant failed to identify missing discovery or prejudice

State v. Locurto, 157 N.J. 463 (narrow standard for de novo review after municipal conviction)
State v. Ebert, 377 N.J. Super. 1 (de novo review must determine whether findings could reasonably be reached on sufficient credible evidence)
State v. Johnson, 42 N.J. 146 (standard for reviewing verdicts against record of proofs)
State v. Kuropchak, 221 N.J. 368 (plenary review of legal determinations)
Clawans v. Schakat, 49 N.J. Super. 415 (routine judicial remarks do not establish disqualifying prejudice)
State v. Marshall, 148 N.J. 89 (bias is not established by disappointment with rulings)