STATE OF NEW JERSEY VS. JEFFREY S. ZEIKEL
Defendant was correctly sentenced as a third-time DWI
offender based on a prior conviction in New Jersey for DWI and
two prior convictions in New York State for driving while
ability impaired. The New York convictions were "of a
substantially similar nature" as a DWI violation in New Jersey.
See N.J.S.A. 39:4-50(a)(3). Defendant's constitutional,
statutory, and factual challenges to the consideration of his
1980s New York convictions are rejected.