State of New Jersey, Plaintiff-Appellant and Cross-Respondent v. Curtis Knight, Defendant-Respondent and…

Summary

The Supreme Court of New Jersey affirmed the Appellate Division's reversal of Curtis Knight's convictions, holding that the State violated the Brady rule by suppressing material exculpatory evidence and that the Sanchez rule on the right to counsel applies retroactively, rendering Knight's statement to an FBI agent inadmissible. The Court also concluded that the FBI agent was acting as an agent of the state, bringing the interrogation within the scope of the state constitutional rule. Justice Coleman, in a partial concurrence and dissent, argued that the Sanchez rule is a new rule and should not be applied retroactively.