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 the date of
her prior, third, unsafe driving offense.
Assistant Editor: Umair Hussain
