State v. Antoine McCray; State v. Sahaile Gabourel

Summary

The Supreme Court of New Jersey held that the Criminal Justice Reform Act does not authorize criminal contempt charges for ordinary violations of pretrial release conditions. The Court distinguished violations of no-contact orders, which may still support contempt prosecutions under State v. Gandhi. The Court reversed the Appellate Division and dismissed the contempt charges against Antoine McCray and Sahaile Gabourel.

Holdings

1. The Criminal Justice Reform Act does not authorize criminal contempt charges for violations of conditions of pretrial release, including a condition prohibiting new offenses or a curfew condition.
2. Violations of no-contact orders imposed as conditions of pretrial release may still be prosecuted as criminal contempt.
3. Because neither defendant was charged with violating a no-contact order, the contempt charges were properly dismissed.

Questions Presented

1. Whether the Criminal Justice Reform Act authorizes criminal contempt prosecutions for violations of nonmonetary conditions of pretrial release.
2. Whether violations of no-contact orders imposed as conditions of pretrial release remain prosecutable as criminal contempt under State v. Gandhi.
3. Whether the defendants' remaining notice and double-jeopardy arguments needed to be addressed after dismissal of the contempt charges.

Disposition

reversed