The New Jersey Supreme Court concluded with the following in relevant part: By any objective measure, from the moment defendant left the hospital, he was in a continued state of law enforcement custody. As a result, the detectives should have given defendant Miranda warnings prior to taking his statement. Whether defendant was viewed as a victim by law enforcement at the time of questioning is not, and has never been, the relevant inquiry under Miranda for determining whether someone is in custody. Defendant’s statement should have been suppressed.
The error in admitting defendant’s statement was harmful, that is, “clearly capable of producing an unjust result.” R. 2:10-2. Crawford, the State’s key witness, testified at trial that his previous statements were false, and he professed defendant’s innocence. Defense counsel presented a defense in line with Crawford’s trial testimony — that defendant was simply in the wrong place at the wrong time. Defendant’s statement to detectives, however, contradicted Crawford’s trial testimony and defendant’s asserted defense; it was thus a damning piece of evidence that cast defendant as a liar.
The State argues that it presented overwhelming evidence of defendant’s guilt “independent of defendant’s statement.” But the State unquestionably relied on the statement in attempting to convince the jury that defendant was guilty, so admission of the statement cannot possibly be viewed as harmless. The judgements of the trial court and appellate division are reversed. The case is remanded for a new trial on the counts of conviction.
The unanimously reversed Appellate Division opinion was unpublished and per curiam. “Per curiam” opinions are said to involve such a straightforward application of the law to the facts that no individual judge had the opportunity to conduct an individualized analysis. There seems to be a growing trend towards issuing these types of opinions in controversial cases as opposed to straightforward cases. This case appears to exemplify that trend. The stakes were high and a three-judge appellate panel was presented with the relatively novel issue of whether status as a victim changed the custodial versus non-custodial Miranda analysis. It seems likely that no judge wanted to attach their name to the opinion because it endorsed a novel and tenuous position advanced by the prosecution, as opposed to being a straightforward application of the law to the facts.
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