The New Jersey Supreme Court continued its love affair with Miranda and Fifth Amendment matters. Here, an interrogating detective administered Miranda warnings to a suspect but “repeatedly undermined them throughout an interrogation.” For example, the detective told the suspect that his confession “would remain confidential among us” and that the warnings were “just a formality.” The Supreme Court ruled that the State did not prove the confession was voluntary. But the Court declined to adopt a bright-line rule that would require suppression any time an officer makes an improper comment during an interrogation.
