State v. Blazas, 74 A.3d 991

Defendant sought to represent himself, Wade hearing approved but without full advisement on consequences.
Prosecution allegedly interfered with defense access to a key witness (McHugh) and police witnesses, prompting pretrial motions.
Defendant proceeded pro se with standby counsel; trial occurred in April 2010 with defendant presenting no testimony.
State’s witnesses included McHugh, Patel, and multiple Sayreville Police Department officers; defendant was convicted of theft, reduced from armed robbery, and acquitted on several counts.
Trial court merged and sentenced under NERA; on appeal, convictions were challenged for improper waiver of counsel and prosecutorial interference with witness interviews.
Court remanded for evidentiary hearing on the interference claim; ultimately reversed convictions due to failure to adequately advise on waiver and unresolved access issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was waiver of counsel knowing and intelligent?	Biazas did not receive Crisafi/Reddish-compliant inquiry.	Defendant understood the proceedings and proficiency supported self-representation.	Waiver of counsel not knowing and intelligent; reversal required.
Did State’s interference with witness interviews deny complete defense?	McHugh and officers were directed not to discuss with defense investigators.	State actions prevented defense access to witnesses, impeding defense preparation.	Yes; interference deprived right to complete defense; remand for evidentiary hearing.
Should defendant receive jail credit adjustments under Hernandez after reversal?	Credit calculation warranted.	Standard Hernandez credit applies to new proceedings.	Remanded; no further Hernandez ruling reached due to reversal.

State v. Crisafi, 128 N.J. 499 (N.J. 1992) (establishes explicit waivers inquiry for self-representation)
State v. Reddish, 181 N.J. 553 (N.J. 2004) (penetrating examination of waiver understanding; broader inquiry)
State v. Feaster, 184 N.J. 235 (N.J. 2005) (prohibition on prosecutorial interference with a witness's testimony)
State v. Budis, 125 N.J. 519 (N.J. 1991) (guarantees of meaningful defense and access to evidence)
State v. King, 210 N.J. 2 (N.J. 2012) (waiver advisement and competency considerations)
State v. DuBois, 189 N.J. 454 (N.J. 2007) (context for Wade hearing and self-representation)
Gregory v. United States, 369 F.2d 185 (D.C. Cir. 1966) (defense access to witnesses; impropriety of restricting interview opportunities)
Washington v. Texas, 388 U.S. 14 (U.S. 1967) (co-indictees' testimony and rights to confront; fundamental fairness)
United States v. Bryant, 655 F.3d 232 (3d Cir. 2011) (prosecutorial interference with access to witnesses violates due process)
State v. Marshall, 148 N.J. 89 (N.J. 1997) (limits on duty to compel interviews; cautions witnesses)