State of New Jersey, Plaintiff-Respondent v. Janet Gelman, Now Known as Caitlin Ryerson, Defendant-Appellant

Summary

The Supreme Court of New Jersey held that the defendant's 1989 petty disorderly persons conviction for solicitation is not a predicate offense under N.J.S.A. 2C:34-1(c)(4), so the fourth-degree prostitution indictment must be dismissed; the Court reversed the Appellate Division, reinstated the trial court's dismissal, and remanded for further proceedings. Justice Rivera-Soto dissented, arguing the statute's language is clear and the indictment should be sustained.