State of New Jersey, Plaintiff-Respondent v. Andrew Henry Lyle, Defendant-Appellant

Summary

The Supreme Court of New Jersey reversed Andrew Henry Lyle's first‑degree murder conviction and remanded for a new trial, holding that the prosecutor's use of Lyle's post‑Miranda silence to attack his self‑defense claim was a plain error violating due process, and that the victim's excited‑utterance statement was admissible. Justice Conford dissented, arguing that Lyle was not silent and that the majority erred in finding a constitutional violation.