State v. Lawrence

Lawrence had been confined to a jail work-release program as a result of his failure to pay child support. When he failed to return to the jail by curfew on two occasions, he was indicted on two counts of third-degree escape. Lawrence pleaded guilty to the charges and was subsequently sentenced. The Appellate Division reversed the conviction and held that an individual on work release for contempt of a civil order cannot be charged with the criminal offense of escape.

Lawrence