State v. Bullock, 253 N.J. 512 (2023)


Janie Byalik argued before the New Jersey Supreme Court on behalf of amicus curiae ACDL-NJ that the state failed to prove beyond a reasonable doubt that the defendant had waived his Fifth Amendment rights, that police misled the defendant regarding his status as a suspect, and that the officers' failure to evaluate whether the defendant later knowingly and intelligently waived his rights rendering both statements inadmissible. The Court affirmed the suppression of both statements. The Court found that the first statement the defendant gave was a custodial interrogation where he was not administered Miranda warnings. The Court further found that the Miranda warnings given later did not render the second statement admissible because at the time of that statement, the defendant "was still operating under the psychological and practical disadvantages of having confessed."

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