A Court, Not the Motor Vehicle Commission, Must Address an Application for Sentencing Credit Related to Installation of an Ignition Interlock Device

State v. Coviello, 252 N.J. 539 (2023). Judge Sabatino’s unanimous opinion in this case began by posing the “narrow jurisdictional question” before the Court as “When a portion of a defendant’s sentence for driving while intoxicated requires the installation of an ignition interlock device (IID), should the defendant’s application for credit toward that portion of the sentence be heard by the sentencing court or the Motor Vehicle Commission (MVC)?” The two courts below had held that the MVC had jurisdiction over that matter. Applying de novo review of this legal issue, the Supreme Court disagreed and reversed.

Judge Sabatino traced the history of statutes that address IIDs. He then focused on key differences between courts and agencies such as the MVC. “Sentencing is a core function of the judiciary …. By contrast, administrative agencies in the Executive Branch are tasked with implementing the terms of sentences imposed by the courts.” Judge Sabatino found that distinction to be embodied in the applicable statutes here. “The plain text and structure of the DWI statutes make it clear that the court has overarching jurisdiction over DWI sentences. The 1999, 2009, and present 2019 versions of the statute have maintained that judicial sentencing role. Most pertinent here, the provision detailing the IID sentencing component refers to ‘the court . . . order[ing]’ the IID as an additional ‘penalty.’ N.J.S.A. 39:4-50.17(b) (2009) (emphasis added). The court’s role in imposing that penalty is repeated throughout the IID provision. See id. at -50.17(a) to (c) (2009).”

Though the MVC has a certain role as to IIDs, “[t]he legislative direction to the MVC to regulate the manner of IID installation and use does not grant authority to modify an IID sentence. Instead, the statute permits the MVC to establish technical rules and requirements to implement the IID sentencing requirement. Id. at -50.21.” The Court distinguished two cases relied on by the Appellate Division, State v. Revie, 220 N.J. 126 (2014), which did not refer to the MVC at all, and State v. Beauchamp, 262 N.J. Super. 532 (App. Div. 1993), where a court “construed its jurisdiction too expansively,” while here judicial jurisdiction “was construed too narrowly.”

The Court was heavily influenced by the brief of the Attorney General as an amicus. The Attorney General did not become involved until after the Supreme Court granted review. Thus, Judge Sabatino “recognize[d] that neither the trial court nor the Appellate Division had the benefit of the input of the MVC and the Attorney General on the jurisdictional issue. Now that we have the benefit of that expertise and advocacy, we are persuaded that we should not foist upon the MVC a sentencing motion that it has no jurisdiction to address. No hearing before the MVC under N.J.A.C. 13:19-1.13(c) was appropriate for modifying or reconsidering the court’s judgment of conviction.” The matter was therefore remanded to the sentencing court for further proceedings.