NJ Supreme Court Rules on Miranda Warnings in Hospital
Docket No. (A-36-22) (087919)
Decided November 20, 2023
Submitted by New Jersey Criminal Lawyer, Jeffrey Hark
In a recent published opinion, the Supreme Court of New Jersey was tasked with determining whether an investigating detective’s self-introduction to defendant at her bedside in the hospital following a car crash initiated a custodial interrogation or its functional equivalent warranting the administration of warnings under Miranda v. Arizona, 384 U.S. 436 (1966).
On April 28, 2020, while driving to Jersey City, defendant crashed into a police officer and then struck two police cruisers. Defendant and three officers were injured as a result. All were transported to Jersey City Medical Center. Defendant’s blood alcohol content was 0.268%, more than three times the legal limit. A detective from the Regional Collision Investigation Unit of the Hudson County Prosecutor’s Office arrived at the hospital and spoke first to the injured officers in the emergency room. The detective then went to speak with the defendant.
There were two uniformed police officers stationed outside the curtain separating defendant’s bed from other patients. The detective approached the defendant’s bed, introduced himself as a detective with the Hudson County Prosecutor’s Office, and explained that he was assigned to investigate the accident. The officer later testified that as soon as he had spoken, the defendant immediately complained of chest pain and said “she only had two shots prior to the crash.” The detective then stated to the defendant not to make any further statements. The detective indicated that he did not go to the hospital to question the defendant and testified that he wanted to interview her at the Prosecutor’s Office at another time. The detective and defendant’s interaction with one another last less than five minutes. Defendant went to the Hudson County Prosecutor’s Office the next day and invoked her Miranda rights.
Defendant was eventually indicted for three counts of assault by auto. Pretrial, the State moved to admit defendant’s statement at the hospital that she “only had two shots prior to the crash.” Following an N.J.R.E. 104(c) evidentiary hearing, the trial judge denied the State’s motion, finding that defendant was in custody in the hospital when she admitted that she had consumed alcohol before the crash and was interrogated because the three officers had reason to know that their presence walking into a hospital room, where the defendant was clearly not free to leave, may elicit an incriminating response or statement made by the defendant. The State appealed the trial court’s decision, which was eventually affirmed by the Appellate Division. The State then filed a motion for leave to appeal, limited to the admissibility of defendant’s statement to police at the hospital, which the Supreme Court of New Jersey granted.
On appeal to the Supreme Court, the State requested the Court reverse the Appellate Division and hold that defendant’s hospital-bed statement was admissible despite the lack of Miranda warnings because it was not the product of interrogation or its functional equivalent under the standard established in Rhode Island v. Innis, 446 U.S. 291 (1980). The State contended that the detective did not ask the defendant any questions, allude to any details about his investigation, or invite any response. The defendant spontaneously and voluntarily complained of chest pain and announced that she had consumed two shots of alcohol prior to the crash. Therefore, the State argued that because this unexpected incriminating statement was made by the defendant while she was in custody in response to “non-investigative” statements by police, the statement fell short of the Innis standard.
Defendant argued that the record supports the trial court’s decision and that, under the totality of the circumstances, the detective should have known that his decision to approach her would reasonably likely to elicit an incriminating response. The defendant contended that the detective had no legitimate purpose in approaching her, and his stated goal of “making contact” to advise her that she was under investigation was properly rejected by both the trial court and the Appellate Division. Defendant further contended that, under Innis, the only reasonable explanation for the detective’s presence was that he was there to obtain information about a criminal investigation.
Ultimately, the Supreme Court of New Jersey reversed the Appellate Court’s decision and remanded the case. The Court held that the defendant was in custody at the hospital in light of the police presence around her bed area, but that no interrogation or its functional equivalent occurred before her spontaneous and unsolicited admission. As a result, Miranda warnings were therefore not required, and defendant’s statement — that she “only had two shots prior to the crash” — is admissible at trial.
At Hark & Hark, we are experienced attorneys who represent clients in Superior Court for issues like the previously discussed case pertaining to motions to suppress statements made in violation of Miranda. We work hard to ensure that our clients receive exceptional representation in order for them to receive the most favorable outcome in their case as a result.
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