New Jersey v. Lane
Annotate this CaseIn 2020, the Legislature amended N.J.S.A. 2C:44-1 to add a new mitigating factor fourteen: “[t]he defendant was under 26 years of age at the time of the commission of the offense.” N.J.S.A. 2C:44-1(b)(14). It provided that “[t]his new act shall take effect immediately.” L. 2020, c. 110, § 2. In this appeal, the Court considers defendant Rahee Lane’s argument that the new mitigating factor should be applied to defendants who were under twenty-six years old at the time of their offenses, if their direct appeals were pending when the statute was amended. The New Jersey Supreme Court construed N.J.S.A. 2C:44-1(b)(14) to be prospective, finding in the statutory language no indication that mitigating factor fourteen applied to defendants sentenced prior to the provision’s effective date. The Court viewed N.J.S.A. 2C:44-1(b)(14)’s legislative history to confirm the Legislature’s intent to authorize sentencing courts to consider the new mitigating factor in imposing a sentence on or after the date of the amendment.
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