Miranda Rights and Spontaneous Statements (Part 1)

by | Jan 3, 2024 | Blog, Criminal Law, Monmouth County, New Jersey, Ocean County

On November 20, 2023, the New Jersey Supreme Court decided the Hudson County case of State v. Amandeep Tiwana. The principal issue concerned whether the functional equivalent of an interrogation occurred that resulted in the defendant’s admission.

Justice Solomon wrote for a unanimous Court in relevant part: The Court considers whether an investigating detective’s self-introduction to defendant Amandeep K. Tiwana 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, defendant, while driving in Jersey City, struck a police officer and collided with two police cruisers. Defendant and three injured officers were transported to Jersey City Medical Center. Defendant’s blood alcohol content was 0.268%, three times the legal limit.

Detective Anthony Espaillat of 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. Two uniformed police officers were stationed outside the curtain separating defendant’s bed from other patients. Detective Espaillat walked up to 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. Espaillat testified that, as soon as he had spoken, defendant immediately complained of chest pain and said “she only had two shots prior to the crash.” Espaillat directed defendant not to make any other statements. He clarified that he did not come to the hospital to ask her questions and that he wanted to interview her at a later date at the Prosecutor’s Office. The entire interaction lasted “less than five minutes.” The next day, defendant went to the Prosecutor’s Office and invoked her Miranda rights.

A grand jury indicted defendant for three counts of assault by auto. Pretrial, the State moved to admit defendant’s statement at the hospital. Following an evidentiary hearing, the trial court denied the State’s motion and the Appellate Division affirmed. Both courts found that a custodial interrogation occurred at the hospital and the detective’s failure to give Miranda warnings rendered defendant’s statement inadmissible.

It is difficult to imagine that the detective introduces himself without intending to elicit an incriminating statement. Under these circumstances, the numerous police that were present would have been considering how to strengthen their case.