Totality of Circumstances Applies to Confession – State v. Knight

This morning’s New Jersey Supreme Court ruling in State v. Knight is a major decision related to both the substantive and procedural law of confessions. The 7-0 opinion, written by Justice Wallace, reverses the Appellate Division decision below.

The facts of the case involve a Newark murder investigation during which the defendant was arrested and questioned by two teams of detectives for an extended period of time, given little food or opportunity to rest. During the interrogation, the defendant was without clothing, save for a hospital-type gown. In addition to a murder confession, detectives also obtained a series of confessions related to a string of bank robberies.

The Supreme Court ruled that the totality of the circumstances test is to be used when deciding whether a confession has been given freely, knowingly and voluntarily. Among the relevant factors in this case were:

Education (some college)
Intelligence Level
Miranda Warnings
Previous encounters with law enforcement
Familiarity with Criminal Justice System
Length of interrogation
Nature of the questioning
Time between Miranda warnings and confession
Use of non-coercive psychological techniques

Procedurally, the Court prohibited the defendant from challenging the voluntariness of his confessions related to the robberies because he had plead guilty to these offenses unconditionally. A plea of guilty acts as a bar to raising constitutional challenges with three narrow exceptions:

1. Denial of a motion to suppress physical evidence;
2. Denial of admittance into PTI
3. Any other denial of a pre-trial motion that is reserved through the use of a conditional plea of guilty.

Download a copy of State v. Knight

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