When the Legislature provided a statutory procedure to recover payment of fines, we declined to construe N.J.S.A. 2C:43-2(d) as conferring authority on a court to impose fines as a “civil penalty”, defendant was both convicted of and pleaded guilty to crimes related to false claims and appraisals he submitted to defraud an insurance company. The […]

The measures enacted by the Legislature to foster collection of restitution, among other payments due from sentenced defendants, did not include civil consent judgments. Although the Legislature enacted sweeping changes to provide compensation to crime victims, it provided spare civil relief – and none involving consent judgments. We are convinced the legislative intent was to […]

On November 16, 2017, a three-judge appellate panel decided the case of State v. Masce. The principal issue was whether the Gloucester County trial court properly rejected the State’s request at sentencing to enter a civil consent judgment against the defendant in favor of the victims. In relevant part, the Court held: Our review of […]