The New Jersey Supreme Court revisited State v. Laurick, in which the Court held that prior uncounseled convictions for driving while intoxicated (DWI) in violation of N.J.S.A. 39:4-50 could not be used to enhance a custodial sentence for a second or subsequent DWI offense. Here, the Supreme Court had to determine whether Laurick relief also prohibits prior uncounseled DWI convictions from serving as predicates to increase a custodial sentence for a later driving while suspended (DWS) conviction under N.J.S.A. 2C:40-26(b). The Court held “that Laurick relief, and the principles underlying the prohibition against the use of uncounseled DWI convictions, extend to the enhanced sentencing scheme in Section 26(b), and that prior uncounseled convictions cannot be used as predicates to increase a loss of liberty for DWS.”