Supreme Court of New Jersey

State of New Jersey, Plaintiff-Respondent v. Michael Hayes, Defendant-Appellant

March 31, 2011205 N.J. 522

Summary

The Supreme Court of New Jersey reversed the Appellate Division and remanded for a full plea‑withdrawal hearing because the trial court unreasonably denied an adjournment that left the defendant without counsel, violating his constitutional right to assistance of counsel at a critical stage. The Court applied the pre‑sentencing "interest of justice" standard under Rule 3:9‑3(e) and instructed the lower court to conduct the hearing with unencumbered counsel.