NJ Supreme Court Clarifies Custodial Interrogation

NJ Supreme Court Clarifies Custodial Interrogation

In State v. Amandeep K. Tiwana (A-36-22/087919) (Decided November 20, 2023), the Supreme Court of New Jersey held that an investigating detective’s self-introduction to the defendant at her bedside in the hospital following a car crash did not constitute a custodial interrogation warranting the administration of warnings under Miranda v. Arizona.

Facts of State v. Tiwana

On April 28, 2020, defendant Amandeep K. Tiwana, 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.

NJ Supreme Court’s Decision in State v. Tiwana

The New Jersey Supreme Court unanimously reversed. “As the parties agree, defendant was in custody at the hospital in light of the police presence around her bed area. But no interrogation or its functional equivalent occurred before her spontaneous and unsolicited admission,” the Court explained. “Miranda warnings were therefore not required, and defendant’s statement – that she ‘only had two shots prior to the crash’ – is admissible at trial.”

As the New Jersey Supreme Court explained, the U.S. Supreme Court held in Rhode Island v. Innis, 446 U.S. 291, 300-01 (1980), that “interrogation” for Miranda purposes occurs when a suspect “is subjected to either express questioning or its functional equivalent,” which may include “any words or actions on the part of the police . . . that the police should know are reasonably likely to elicit an incriminating response from the suspect.” At the same time, the Supreme Court emphasized that the police “cannot be held accountable for the unforeseeable results of their words or actions.”

In this case, the New Jersey Supreme Court found that the defendant was not subject to a custodial interrogation or its functional equivalent when she stated that she “only had two shots prior to the crash.” In support of its decision, the Court cited that no questioning occurred, and Espaillat could not have foreseen that his introduction was reasonably likely to elicit an immediate incriminating response. Rather, defendant spontaneously made an unsolicited incriminating statement while in custody.

“Although Detective Espaillat approached defendant after she provided her medical history to hospital staff, he did not engage in what the Supreme Court termed particularly ‘evocative’ conduct reasonably likely to yield incriminating statements from defendant,” the Court wrote. “Rather, defendant spontaneously made an unsolicited incriminating statement while in custody…” With regard to the trial court and Appellate Division’s reliance on the three police officers in or just outside defendant’s bed area at the time Espaillat introduced himself, the New Jersey Supreme Court noted that while that fact alone may establish custody, it does not establish interrogation.

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