11-10-09 Hina K. Patel v. New Jersey Motor Vehicle Commission
(A-86-08)
Under N.J.S.A. 39:4-97.2(e), the exemption provision for assessing motor vehicle penalty points for an unsafe driving offense that occurs more than five years after “the prior offense,” “the prior offense” refers only to the most recent preceding offense based on both a plain reading of the statute and a review of the legislative history. Thus, the Motor Vehicle Commission correctly imposed motor vehicle points on Patel for having a fourth unsafe driving conviction in 2007, only one year after thher prior, third, unsafe driving offense.
Assistant Editor: Umair Hussain
