State of New Jersey, Plaintiff-Appellant v. Ryan Lee Alexander, Defendant-Respondent

Summary

The Supreme Court of New Jersey reversed the defendant's conviction under N.J.S.A. 2C:35-3 because the trial court failed to instruct the jury that the defendant must have occupied a high-level, supervisory position in the drug‑trafficking network. The Court held that such a definition is a material element of the offense consistent with legislative intent and remanded for a new trial with proper jury instructions. Justice Clifford dissented, arguing that the majority rewrites the statute by adding a new element and would reinstate the conviction.