State of New Jersey v. Stephon G. Wright
133 A.3d 656
N.J. Super. Ct. App. Div.2016Background
- Wright pled guilty conditionally to first-degree armed robbery under a negotiated plea agreement.
- The trial court denied motions to suppress the victim’s identification and Wright’s statements.
- The victim identified Wright at a showup, after police indicated they had the robber and had recovered items.
- Wright was in custody during portions of the pre-identification interrogation, and Miranda warnings were not given before some questioning.
- The court admitted the identification and denied suppression of the statements; the defense appealed under Rule 3:9-3(f).
- The Appellate Division reversed the admission of Wright’s statements and remanded for further proceedings; identification admission was affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the showup identification was admissible under Henderson. | Wright | Wright contends substantial likelihood of irreparable misidentification. | Identification admissible under Henderson framework. |
| Whether Wright’s statements to police were the Miranda equivalent of interrogation. | State | Wright’s statements were compelled by custodial interrogation. | Statements must be suppressed; remand for proceedings consistent with Miranda. |
| Whether Delgado disclosure defects warranted exclusion of identification. | State | Delgado documentation was inadequate. | Delgado issue not reviewable due to lack of record; argument rejected. |
| Whether Wright’s sentence was properly imposed. | State | Challenge to double counting and aggravating factors. | Sentence upheld; arguments rejected as meritless. |
Key Cases Cited
- State v. Henderson, 208 N.J. 208 (N.J. 2011) (framework for assessing identification reliability balancing system/estimator variables)
- State v. Bey, 112 N.J. 45 (N.J. 1988) (functional equivalent of interrogation standard)
- State v. Ward, 240 N.J. Super. 412 (N.J. Super. Ct. App. Div. 1990) (pre-Miranda interrogation analysis in cell-edge confrontations)
- In re Rhode Island v. Innis, 446 U.S. 291 (U.S. Supreme Ct. 1980) (defining interrogation as words/actions reasonably likely to elicit an incriminating response)