State v. C.H. (A-56-15; 076535)
Defendant’s sentences should be viewed together and jail credit applied to the front end of the aggregate imprisonment term for both indictments. To the extent that State v. Hernandez, 208 N.J. 24 (2011), has been read differently with respect to consecutive sentences, Hernandez is modified as follows: double credit should not be awarded where a defendant is sentenced to
consecutive sentences under separate indictments and
receives the optimal benefits of jail credit for time
spent in pre-sentence custody. Instead, the sentencing
court should treat the sentences as a unified proceeding
and maximize the benefits to the defendant by applying
jail credit to the front end of the imprisonment term.