State v. Michael Konecny (084880) (Monmouth County & Statewide)

Summary

The Supreme Court of New Jersey held that Laurick relief—prohibiting the use of prior uncounseled DWI convictions to enhance a sentence—extends to the enhanced sentencing scheme of Section 26(b) for driving while suspended, that a conviction vacated through traditional post‑conviction relief cannot serve as a predicate for a Section 26(b) prosecution, and that Laurick relief is unavailable where the defendant had counsel at the prior conviction; consequently the Court affirmed the defendant’s 180‑day sentence.