State of New Jersey v. Charles Puryear, 117 A.3d 1255

Background

On Dec. 5, 2011, co-defendants Charles Puryear and Markus Brown (arrested after a motel robbery) each gave two recorded custodial statements after Miranda warnings: an early morning interview by State Police about the Sussex County motel robbery and later interviews by Essex County detectives about a Newark homicide.
Each interview began with Miranda warnings and a written waiver; both defendants made incriminating statements in the recordings.
Trial court initially admitted all four statements but, on reconsideration, suppressed one statement for each defendant: Puryear’s first (Sussex robbery) and Brown’s second (Essex homicide), while admitting the converse statements.
The court’s suppression rulings turned on two officer explanations given during the waiver process: (1) an officer told Puryear “you can only help yourself” by talking, which the court found undermined the Miranda warning that statements can be used against a suspect; and (2) an Essex detective told Brown that “anything you say . . . meaning if you lie, it can be used against you,” which the court found to be an incorrect/misleading explanation of the warning that statements can be used in court.
The State and defendants appealed the reconsideration order. The Appellate Division affirmed: it upheld suppression of Brown’s second statement and of Puryear’s first statement, and affirmed admission of Puryear’s second statement.

Issues

Issue	State's Argument	Defendant's Argument	Held
1) Did trial court properly grant reconsideration of its initial admission rulings?	Reconsideration improper; initial rulings were correct.	Reconsideration proper to correct overlooked misleading officer statements.	Reconsideration was appropriate; court did not abuse discretion.
2) Was Brown’s second (Essex) statement admissible despite detective’s misleading explanation of Miranda warning that statements can be used in court?	In context Brown merely worried about testifying; prior record showed he understood warnings.	The detective’s explanation contradicted Miranda and vitiated a knowing waiver.	Suppression affirmed: explanation was incorrect, State failed to prove a knowing, intelligent waiver.
3) Was Puryear’s first (Sussex) statement admissible despite officer saying “you can only help yourself” by talking?	The remark merely reflected overwhelming evidence; Puryear understood Miranda.	The comment contradicted Miranda and neutralized the warning that statements can be used against him.	Suppression affirmed: the officer’s statement was misleading and the State didn’t prove waiver beyond a reasonable doubt.
4) Was Puryear’s second (Essex) statement admissible though given hours after the contaminated first interview?	Second interview was by different officers, with fresh Miranda warnings and forms; cured any prior contamination.	The earlier misleading statement contaminated the later waiver (question-first, warn-later/Seibert-analogous).	Admission affirmed: sufficient break and fresh warnings; waiver found knowing, voluntary, intelligent.

Key Cases Cited

Miranda v. Arizona, 384 U.S. 436 (establishes Miranda warnings requirement)
Missouri v. Seibert, 542 U.S. 600 (warns that question-first, warn-later interrogation can render Miranda ineffective)
Michigan v. Mosley, 423 U.S. 96 (police must scrupulously honor invocation of right to silence)
Edwards v. Arizona, 451 U.S. 477 (limits re-initiation of interrogation after request for counsel)
State v. Nyhammer, 197 N.J. 383 (State must prove waiver beyond a reasonable doubt; defer to trial court fact findings)
State v. Miller, 76 N.J. 392 (permissible truthful appeals to tell truth distinct from misleading assurances)
State v. Pillar, 359 N.J. Super. 249 (officer assurances that statements could be made "off‑the‑record" can render confession inadmissible)
State ex rel. A.S., 203 N.J. 131 (suppression where officer told suspect answering would "actually benefit" her, contradicting Miranda)
State v. Diaz-Bridges, 208 N.J. 544 (appellate review of recorded interrogation evidence may be de novo)
State v. Knight, 183 N.J. 449 (relevant factors for voluntariness include prior encounters with law enforcement)