The issues in this appeal are whether defendant's conviction for a fifth offense of driving while intoxicated (DWI) should be reversed on the ground that trial counsel rendered ineffective assistance by refusing to present a psychiatric defense and whether defendant was entitled to a jury trial given the 180-day sentence imposed. The court affirms the tenet that DWI is a strict-liability offense for which mental-state defenses are unavailable and that defendant is not entitled to a jury trial where the period of incarceration does not exceed six months.
Here, defendant was convicted following a municipal court bench trial at which he admitted to consuming alcohol, exhibited indicia of intoxication, and failed field sobriety tests. Although defendant attributed his conduct to persecutory paranoia and amnesia unrelated to alcohol use, his trial counsel declined to pursue a psychiatric defense. The court holds that counsel's decision was reasonable and compelled by law, as mental-state defenses such as insanity are not viable in DWI prosecutions. In so holding, the court adopts as precedent the case of State v. Inglis, 304 N.J. Super. 207 (Law Div. 1997).
Counsel's refusal to advance a legally untenable defense did not fall below professional standards. Nor did the sentence of 180 days in county jail entitle defendant to a jury trial. The court reaffirms that a single petty offense subject to no more than six months' incarceration does not meet the threshold for jury-trial protections, even when accompanied by significant collateral penalties such as years-long license suspension and installation of an ignition interlock device. The conviction and sentence are affirmed.