N.J. Supreme Court reverses ruling that had expanded Miranda rights
Justice Anne M. Patterson (Courtesy of New Jersey Courts)
The New Jersey Supreme Court declined to make a sweeping change to Miranda rights rules in a 3-2 decision Wednesday that the two dissenting judges said will “erode faith in our criminal justice system.”
The opinion reverses a lower court ruling that had been in favor of Anthony Sims Jr., a man convicted of a 2014 attempted murder in Red Bank. Sims claimed his Miranda rights were violated after his arrest because officers didn’t say they suspected he committed the crime before they interrogated him, but the court’s ruling says officers are required to tell suspects only about existing charges they face, not charges they may face in the future.
Anything else would be unworkable, Justice Amy Patterson wrote in her majority ruling, “because it would require police officers to speculate on the charges that an arrestee might face when no judge has issued a complaint-warrant or arrest warrant.”
Patterson’s opinion was joined by Chief Justice Stuart Rabner and Justice Lee Solomon. Justices Barry Albin and Fabiana Pierre-Louis dissented, with Albin saying defendants can’t have a fair trial if they waive their Miranda rights without being properly informed of the charges they face.
Patterson also dismissed Sims’ claim that his victim’s pretrial testimony was improperly introduced as evidence at his trial (the victim, who was later indicted for killing Sims’ brother, did not testify at Sims’ trial).
The chief issue in Sims’ case is whether he knowingly and voluntarily waived his Miranda rights.
The attempted murder took place on April 9, 2014. The victim sustained 12 gunshot wounds and later identified his shooter to police as Sims. Officers arrested Sims and, before a two-hour interrogation, Sims waived his Miranda rights. He then denied to police that he was involved in the shooting.
Sims was indicted on attempted murder and weapons charges. He moved to suppress his statement to police, alleging officers used deceptive techniques during the interview and should have repeated their Miranda warning. The trial judge denied Sims’ bid to suppress the interview.
After he was convicted on all charges and sentenced to 50 years in prison, Sims appealed, alleging for the first time that officers violated his Miranda rights by not telling him before his interrogation why he had been arrested. An appellate panel sided with Sims, relying on a prior state Supreme Court decision that renders Miranda waivers invalid if police do not inform a defendant that a criminal complaint has been filed or an arrest warrant has been issued against them.
The appellate judges also agreed with Sims that the pretrial testimony of his victim should not have been introduced at trial because it deprived Sims of his right to confront his accuser and violated the rule against hearsay.
After Sims’ conviction was tossed, the Monmouth County Prosecutor’s Office appealed to the Supreme Court.
Patterson said the appellate ruling misinterprets the Supreme Court’s earlier rulings on when suspects must be notified of the charges they face. If a warrant has been issued, Patterson’s newest decision says, then police must tell the suspect so the suspect can knowingly waive their Miranda rights. But in Sims’ case, there was no warrant yet, Patterson noted.
The appellate court’s attempted expansion of Miranda rights “relies not on an objective statement of the charges pending against the arrestee, but on an officer’s prediction, based on information learned to date in a developing investigation, of what charges may be filed,” the opinion says. “An officer acting in good faith might inadvertently misinform an arrestee as to the charges that he will eventually face.”
Albin said he would have reversed Sims’ murder conviction on the grounds of the state’s laws against self-incrimination, and agrees with the lower court’s decision that informing defendants of their charges is critical when a suspect has to determine whether to waive their Miranda rights.
“Without that critical information, a defendant cannot intelligently decide whether to waive his right against self-incrimination. That other charges may develop during the investigation is no excuse for officers to withhold the specific charges that prompted a defendant’s arrest,” Albin wrote.
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