LANE v. THE ATTORNEY GENERAL OF THE STATE OF NEW JERSEY, 3:15-cv-04108

In 2007 Travis Lane (then 17) was convicted by a jury of aggravated manslaughter (lesser-included), felony murder, armed robbery, and unlawful possession of a knife; after merger he received a 40‑year term with an 85% NERA parole bar.
The charged homicide followed a street altercation in which witnesses placed Lane at the scene; several eyewitnesses and a pretrial statement implicating Lane were admitted at trial.
Lane was arrested at school four days after the killing, Mirandized in the presence of his mother, and gave a videotaped written statement he later recanted as coerced.
At the suppression hearing the defense presented Dr. Siegert (psychologist) who opined Lane had intellectual deficits (IQ around 60–70) and could not understand Miranda; the State’s expert Dr. Schlesinger disputed those findings and concluded Lane understood his rights.
The trial court found the detectives credible, credited the State expert and Lane’s lay testimony as sufficient, denied suppression, and admitted the statement; New Jersey courts affirmed on direct appeal and denied PCR relief.
Lane filed a federal habeas petition raising (1) involuntary/unknowing Miranda waiver and (2) ineffective assistance for counsel’s failure to investigate/replace Siegert; the District Court denied relief and a COA.

Issue	Plaintiff's Argument (Lane)	Defendant's Argument (State)	Held
Validity of Miranda waiver / voluntariness of confession	Lane lacked capacity (low IQ, cognitive deficits, ADHD) and was coerced (threats) so his waiver and confession were not knowing/voluntary	Totality of circumstances shows valid waiver: mother present, Mirandized, short interval to statement, experts conflicted but State’s expert and detectives credible	Denied — state courts’ finding that waiver was knowing/voluntary was not an unreasonable application of federal law nor an unreasonable factual determination
Ineffective assistance for not investigating or replacing defense expert Siegert	Counsel failed to investigate Siegert’s credentials and should have sought a continuance to obtain a competent expert; prejudice follows	Counsel reasonably relied on an experienced expert previously used; counsel strategically declined to call Siegert at trial to avoid impeachment; petitioner offered no affidavit of an available better expert or proof of prejudice	Denied — counsel’s conduct fell within reasonable professional assistance and Lane failed to show prejudice under Strickland
Certificate of Appealability (COA)	Lane argued constitutional errors warrant appeal	Court: petitioner has not made a substantial showing of the denial of a constitutional right	Denied — COA not warranted

Miranda v. Arizona, 384 U.S. 436 (1966) (custodial confessions barred unless accused is advised of rights and waiver is voluntary, knowing, and intelligent)
Moran v. Burbine, 475 U.S. 412 (1986) (two-part totality inquiry for Miranda waiver: voluntariness and knowing/intelligent aspect)
Fare v. Michael C., 442 U.S. 707 (1979) (totality approach adequate for juveniles; consider age, education, intelligence)
Colorado v. Connelly, 479 U.S. 157 (1986) (police coercion is required predicate for confession to be involuntary under Due Process)
Withrow v. Williams, 507 U.S. 680 (1993) (voluntariness depends on totality: coercion, length/place of interrogation, maturity, intelligence, mental health)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance of counsel: deficient performance and prejudice)
Harrington v. Richter, 562 U.S. 86 (2011) (AEDPA deference to state-court adjudications; ask whether any reasonable argument supports counsel’s performance under Strickland)
Slack v. McDaniel, 529 U.S. 473 (2000) (standard for granting a certificate of appealability)