Prayer for judgment continued or a “PJC” is a common disposition in criminal cases, most frequently for traffic law violations or low-level crimes, where entry of final judgment is delayed indefinitely. We have previously covered when conditions on a PJC convert it to a final judgment, limits on the use of PJCs, sex offender registration and PJCs, whether a PJC can be expunged, collateral consequences of PJCs, and other contexts where questions about PJCs arise. A case from the Court of Appeals last year has generated renewed interest in dispositional PJCs. Dispositional or “true” PJCs typically serve as the final resolution of a case. This is in contrast with PJCs used to continue judgment for a set period of time so the defendant can satisfy some condition or for the court to otherwise remain involved in the case. Today’s post will examine that decision, offer thoughts on how defenders can mitigate the potential risk of a dispositional PJC, and discuss how an unwanted PJC might be avoided altogether. McDonald had a PJC—Until He Didn’t. The defendant in State v. McDonald, 290 N.C. App. 92 (Aug. 1, 2023), pled guilty to one count of misdemeanor death by motor vehicle in Robeson County Superior Court in 2014. Under the terms of the plea, the defendant agreed to accept responsibility for the accident in open court and pay the court costs in exchange for a PJC disposition. Around six years later in 2020, the defendant was involved in another fatal car accident, leading this [...]
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