State of New Jersey, Plaintiff-Appellant v. Carl Hreha Defendant-Respondent

Summary

The New Jersey Supreme Court reversed in part the Appellate Division's decision that the State failed to prove beyond a reasonable doubt that the defendant voluntarily waived his Miranda rights, and remanded for a new Miranda hearing. The Court held that the trial court’s factual finding that no promises of leniency were made was unsupported by sufficient credible evidence. It also held that the State had not met its burden to show a voluntary waiver. The case was sent back for a fresh credibility assessment.