In the case of State v. Amandeep Tiwana, decided on November 20, 2023, the New Jersey Supreme Court reversed the lower courts’ decisions, ruling that the statement made by Amandeep Tiwana in a hospital bed was admissible in her trial. The key issue was whether the introduction of Detective Espaillat to Tiwana at the hospital following her involvement in a car crash constituted a custodial interrogation or its functional equivalent, requiring Miranda warnings. Id. at ___ (slip op. at 2).

On April 28, 2020, Tiwana, while driving, struck a police officer and collided with two police cruisers. With a blood alcohol content of 0.268%, she was taken to the hospital, where Detective Espaillat introduced himself and informed her he was investigating the accident. Tiwana spontaneously stated she had “only had two shots before the crash.” Id. at ___ (slip op. at 2). The trial court ruled this statement inadmissible, considering it resulted from a custodial interrogation without Miranda warnings, and the Appellate Division affirmed. Id. at ___ (slip op. at 5-6).

The Supreme Court, however, reversed and found that Tiwana was not subjected to interrogation or its “functional equivalent” when she spontaneously made her statement that she “only had two shots prior to the crash.” Id. at ___ (slip op. at 16). The Court determined that no questioning occurred, and that Detective Espaillat could not have foreseen that his introduction was likely to elicit an incriminating response. Consequently, the Court held that Tiwana’s spontaneous, unsolicited statement was admissible, emphasizing that the presence of police officers alone does not constitute interrogation. Id. at ___ (slip op. at 16).

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