Supreme Court of New Jersey

Patel v. Nj Motor Vehicle Com'n

November 10, 2009200 N.J. 413

Summary

The Supreme Court of New Jersey affirmed the Appellate Division's decision, holding that the Motor Vehicle Commission correctly assessed motor vehicle penalty points for Hina Patel's fourth unsafe driving conviction because the statutory exemption applies only when the offense occurs more than five years after the immediately preceding offense. The Court interpreted the phrase “the prior offense” in N.J.S.A. 39:4-97.2(e) to refer to the most recent prior offense.