STATE OF NEW JERSEY v. ANDREAS M. ERAZO (17-10-1376, MONMOUTH COUNTY AND STATEWIDE) (RECORD IMPOUNDED), A-4408-18

An 18‑year‑old defendant was taken to the Keansburg Police Department after an 11‑year‑old neighbor was reported missing and later found dead on a roof beneath a window to his apartment.
Police twice searched the defendant's apartment; detectives interviewed him first in the station (about 1.5 hours) without Miranda warnings while he sat in a secured area and was not told he was free to leave.
Between the first and second interviews detectives obtained additional inculpatory information (witness account, items from the apartment linked to the victim).
Several hours later detectives gave Miranda warnings, obtained a signed waiver, and recorded a second, longer interview in which the defendant confessed; detectives used information from the earlier unwarned interview and made statements minimizing seriousness and promising help.
Trial court denied suppression, defendant pled guilty and was sentenced to life with NERA parole ineligibility. On appeal the Appellate Division reversed the suppression ruling and remanded to allow withdrawal of the plea or other disposition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the first interview custodial so that Miranda warnings were required?	State: interview was noncustodial, part of a witness interview; no restraints.	Defendant: transported in marked police car, confined to secured area, not told he could leave, escorted for breaks — objectively custodial.	Appellate court: first interview was custodial; trial court erred. Statements suppressed.
Was the second interview waiver voluntary and effective given the two‑step interrogation and officers' conduct?	State: warnings were given, defendant signed waiver, breaks and refreshments provided, waiver was knowing and voluntary.	Defendant: warnings were undermined by prior unwarned interrogation, officers minimized significance, withheld suspect status and did not tell him pre‑warning statements couldn’t be used; waiver invalid.	Appellate court: waiver was ineffective; second statement was product of continued/unattenuated interrogation and improper minimization — suppressed.
Sentencing/Miller challenge to life sentence for an 18‑year‑old	State: sentence lawful under plea and NERA.	Defendant: life with NERA for an 18‑year‑old violates Eighth Amendment / Miller principles or, alternatively, youth should be considered as mitigating.	Appellate court: did not reach sentencing issues because suppression required reversal; sentencing claims left for further proceedings.

Miranda v. Arizona, 384 U.S. 436 (established custody/interrogation warnings requirement)
California v. Beheler, 463 U.S. 1121 (formal arrest not always required for Miranda custody analysis)
State v. O'Neill, 193 N.J. 148 (two‑step/"question first, warn later" framework and factors to evaluate attenuation)
State v. Carrion, 249 N.J. 253 (application of O'Neill factors and burden to prove waiver beyond a reasonable doubt)
State v. Tillery, 238 N.J. 293 (standards for knowing, intelligent, and voluntary Miranda waiver)
State v. L.H., 239 N.J. 22 (limits on minimization and promises that undermine Miranda)
State v. Hubbard, 222 N.J. 249 (custody and interrogation definitions; Miranda application)