State of New Jersey, Plaintiff-Respondent v. Phillip Presha, Defendant-Appellant

Summary

The Supreme Court of New Jersey affirmed the Appellate Division, holding that the juvenile defendant's confession was voluntary and admissible. It reaffirmed the totality‑of‑circumstances test for juvenile confessions and declared that the absence of a parent is a highly significant factor. The Court also established a bright‑line rule that any confession obtained from a juvenile under fourteen without a parent present is inadmissible as a matter of law unless the parent is truly unavailable.