State v. Daryel Rawls (072388)
219 N.J. 185
| N.J. | 2014Background
- Aug. 8, 2010: Rawls arrested in Union County after police recovered heroin; Union County grand jury indicted him on multiple drug-related counts.
- Rawls posted bail (Aug. 18, 2010) on the Union County indictment and remained free until Oct. 17, 2010, when he was arrested in Ocean County on separate, serious drug charges and did not make bail.
- Rawls spent 155 days in Ocean County custody before pleading guilty in Union County on Mar. 21, 2011; his Union County bail was revoked that same day.
- At sentencing (Sept. 9, 2011) Rawls received 53 days of jail credit (11 days pre‑bail and 42 days gap credit), but the trial court denied credit for the 155 days in Ocean County custody prior to his Union County plea.
- The Appellate Division affirmed; the New Jersey Supreme Court granted certification and, applying State v. Hernandez, reversed and remanded to award the additional 155 days of jail credit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a defendant who posted bail on one indictment but was later incarcerated on a different indictment is entitled to pre‑sentence jail credit on the first indictment for the period of subsequent incarceration | State: Rawls posted bail on the Union County matter and then committed a new offense; therefore credit for the later incarceration should apply only to the new (Ocean County) case | Rawls: Under Rule 3:21-8 as interpreted in Hernandez, jail credit applies to each case for time served between arrest and sentence, regardless of bail status or which charge directly caused incarceration | The Court held Rawls is entitled to the 155 days of jail credit on the Union County sentence; Hernandez controls and revocation or posting of bail is immaterial |
Key Cases Cited
- State v. Hernandez, 208 N.J. 24 (2011) (interpreting R. 3:21-8 to require jail credit on each case for time served between arrest and sentencing)
- Richardson v. Nickolopoulos, 110 N.J. 241 (1988) (jail credits as pre-sentence credit reducing custodial terms)
- State v. Black, 153 N.J. 438 (1998) (pre-Hernandez articulation of the "directly attributable" confinement rule)
- Booker v. N.J. State Parole Bd., 136 N.J. 257 (1994) (jail credits applied to the "front end" of a sentence)
- State v. Hemphill, 391 N.J. Super. 67 (App. Div.) (2007) (discussing mandatory nature of jail credits when Rule conditions are met)