New Jersey v. Wint

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Law enforcement officers arrested defendant Laurie Wint on a New Jersey murder charge and brought him to the Camden County Prosecutor’s Office for questioning. Wint invoked his right to counsel after receiving Miranda warnings, and the interrogation ceased. Immediately afterwards, two detectives from Pennsylvania investigating an unrelated murder in Bucks County entered the interrogation room to question Wint. After receiving his rights for the second time, Wint again requested the presence of counsel, ending the interrogation. Wint remained in continuous pre-indictment custody in Camden County when, six months later, he was transported to Bucks County. There, Pennsylvania detectives again administered Miranda warnings but did not provide counsel as Wint had earlier requested. This time, Wint waived his rights and allegedly incriminated himself in the New Jersey murder. The trial court denied Wint’s motion to suppress his incriminating remarks believing that Wint reinitiated communication with the Pennsylvania detectives. With the admission of Wint’s incriminating statements at trial, a jury convicted Wint of passion/provocation manslaughter and other related offenses. The issues this case presented for the New Jersey Supreme Court's consideration centered on whether Pennsylvania detectives violated Edwards v. Arizona, 451 U.S. 477 (1981), by attempting to question defendant in Camden and later questioning him in Pennsylvania after he earlier requested counsel. The Court also considered the exceptions to the rule requiring the suppression of any statement secured during a subsequent custodial interrogation after a defendant requests counsel: whether (1) counsel was provided during the questioning, (2) defendant initiated the communication, or (3) a break in custody occurred. The Court concluded the Pennsylvania detectives violated Edwards by attempting to question Wint in Camden after his earlier request for counsel, and Wint did not initiate the interrogation that occurred in Bucks County. The giving of repeated Miranda warnings did not cure the Edwards violation. Pre-indictment, pretrial detainment did not qualify as a break in custody under Maryland v. Shatzer, 559 U.S. 98 (2010), and none of the exceptions set forth in Edwards applied here. Edwards required suppression of Wint’s incriminating statement concerning the shooting in Camden; the admission of that statement was not harmless error. View "New Jersey v. Wint" on Justia Law