Supreme Court of New Jersey
State of New Jersey in the Interest of K.O., a Minor
February 24, 2014217 N.J. 83
Summary
The New Jersey Supreme Court held that N.J.S.A. 2A:4A-44(d)(3) requires two separate prior juvenile adjudications—one involving incarceration—before a juvenile may receive an extended‑term sentence, excluding the present offense, and therefore reversed the extended‑term sentence. The Court also noted that statutory interpretation is reviewed de novo and applied the doctrine of lenity where ambiguity existed. A concurrence agreed with the result but offered a slightly different reasoning.