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NJ DUI Case Law Update: State v. Coviello (2023)

January 8, 2026

State v. Coviello (2023): NJ Supreme Court Clarifies Ignition Interlock Authority in DUI Cases

Case: State v. Coviello, 252 N.J. 539 (2023)
Court: Supreme Court of New Jersey
Topic: DUI sentencing, ignition interlock devices (IID), court vs. MVC authority

Key Holding

In State v. Coviello, the New Jersey Supreme Court held that the sentencing court—not the Motor Vehicle Commission (MVC)—has jurisdiction over motions seeking credit or modification related to ignition interlock device (IID) requirements imposed as part of a NJ DUI sentence.

What the Court Decided

The defendant, a second-offense DWI offender, was ordered to install an IID for two years after completing a license forfeiture period. She never installed the device, claiming she had no access to a vehicle. Years later, she sought credit toward the IID portion of her sentence.

Both the trial court and Appellate Division ruled that only the MVC could address the issue. The Supreme Court reversed, making clear that:

  • Sentencing is a core judicial function
  • IID requirements are part of the criminal sentence
  • The MVC’s role is administrative only
  • Only the sentencing court may decide whether relief or credit is appropriate

Why This Matters in NJ DUI Cases

This decision is significant for defendants facing ignition interlock penalties, especially where compliance was delayed or impossible due to lack of vehicle access. It confirms that courts retain continuing authority over DUI sentences, including non-custodial penalties like IID installation.

Practical Takeaway

If there is a dispute about how an IID requirement should be applied, credited, or modified, the proper forum is the sentencing court—not the MVC. These issues raise legal and factual questions that require judicial review.


Anthony J. Vecchio, Esq.
New Jersey DUI & Criminal Defense Attorney
Former Municipal Prosecutor
Law Office of Anthony J. Vecchio, LLC

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