State of New Jersey, Plaintiff-Petitioner v. Frank M. Miller, Jr., Defendant-Respondent

Summary

The Supreme Court of New Jersey reversed the Appellate Division and remanded for a new trial, holding that the defendant's confession was involuntary and therefore inadmissible, and that the substitution of an alternate juror after deliberations violated the defendant's constitutional right to a fair jury trial. The Court based its decision on a totality‑of‑circumstances analysis of the interrogation and on the prejudice caused by the late juror substitution. A dissent (Conford) would have affirmed the conviction, and a partial concurrence/dissent (Pashman) agreed on the confession issue but upheld the juror‑substitution rule as facially valid.