STATE OF NEW JERSEY v. CINDY KEOGH (19-05-0288, SOMERSET COUNTY AND STATEWIDE), A-1355-21

Jan. 9, 2019: Terrence Coulanges was shot and died at the Keogh property; Ryan admitted he shot Coulanges and was later Mirandized.
Cindy called 9-1-1; officers arrived, secured the scene, and directed Cindy to summon David and Ryan; officers found Coulanges on the carriage-house porch.
The three Keoghs were transported to police headquarters, separated, and interviewed; Detective Randy Sidorski recorded Cindy’s (~25 min) and David’s (~18 min) statements without Miranda warnings; Ryan was interviewed later with warnings.
The trial court suppressed Cindy’s and David’s statements, finding they were in custody and subjected to custodial interrogation without Miranda warnings; the State appealed.
The Appellate Division reversed: it held Cindy and David were not in custody nor subjected to custodial interrogation, and the court exercised original jurisdiction to find the statements voluntary beyond a reasonable doubt.
Case remanded for further proceedings; the court did not reach the State’s alternative argument about suppressing crimes committed during interviews.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Cindy and David were "in custody" such that Miranda warnings were required	State: interactions were investigatory, temporary, and did not amount to a significant deprivation of freedom	Keogh: separation, escort to HQ, police commands, inability to return home while warrants executed meant a reasonable person would not feel free to leave	Reversed suppression — not custody under the totality of circumstances; investigatory detention, they were told they could leave and in fact left that night
Whether questioning amounted to "custodial interrogation" or the functional equivalent under Innis	State: questioning was conversational and investigative, not designed to elicit incriminating responses from Cindy and David	Keogh: questioning about a dead body on their property was reasonably likely to elicit incriminating responses	Reversed suppression — questioning was investigative/non‑confrontational; no functional equivalent of interrogation shown
Whether Miranda can be applied to suppress crimes committed during police interviews	State argued Miranda should not be a shield for new crimes confessed during interviews	Keogh advanced general Miranda protection arguments	Not decided — appellate court found other grounds dispositive and expressly declined to address this novel argument

Miranda v. Arizona, 384 U.S. 436 (Miranda custodial‑interrogation rule)
Rhode Island v. Innis, 446 U.S. 291 (functional equivalent of interrogation test)
State v. Hubbard, 222 N.J. 249 (Miranda requires custody + interrogation)
State v. P.Z., 152 N.J. 86 (discussion of custody for Miranda purposes)
State v. O'Neal, 190 N.J. 601 (totality‑of‑circumstances test for custody)
State v. Timmendequas, 161 N.J. 515 (non‑targeted investigative questioning not Miranda custodial interrogation)
State v. Smith, 374 N.J. Super. 425 (on‑scene investigative questioning not custodial)
State v. L.H., 239 N.J. 22 (State must prove voluntariness of statements beyond a reasonable doubt)