STATE OF NEW JERSEY VS. LAUREN M. DORFF (18-10-0804, CAPE MAY COUNTY AND STATEWIDE), A-2485-19

In July and August 2018 Dorff was twice custodially interrogated (both sessions videotaped) after a man who shared a child with her died of an apparent overdose.
At the July 22 interview Dorff admitted taking money from the victim but denied selling him pills; the trial court found her Miranda waiver and statements voluntary and admissible.
At the August 10 interview Dorff repeatedly mentioned needing an attorney; after equivocal colloquy she admitted selling the victim pills.
During the August 10 interview a Cape May County detective told Dorff, in substance, that if she "didn't do anything" she would not need a lawyer—an offhand remark the court found problematic on appeal.
The trial court denied suppression of both statements; Dorff pled guilty to first‑degree strict liability for drug‑induced death and appealed the suppression rulings.
The Appellate Division affirmed admissibility of the July 22 statement but reversed suppression denial for the August 10 statement, holding the detective's remark impermissibly burdened the right to counsel under Miranda/Edwards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Dorff's July 22 Miranda waiver knowing, intelligent, and voluntary?	State: warnings were given, environment non‑coercive, Dorff was alert and never invoked counsel.	Dorff: prior relationship with one detective and interrogation techniques rendered the waiver involuntary.	Affirmed: waiver and statements voluntary and admissible.
Did police fail to scrupulously honor Dorff's invocation of right to counsel at August 10 interview?	State: detectives largely clarified and deferred to Dorff; any references were not an invocation requiring cessation.	Dorff: she repeatedly asked about counsel and was told she "didn't need" a lawyer if she did nothing wrong, which deterred invocation.	Reversed: detective's comment burdened right to counsel; Miranda/Edwards violation requires suppression of post‑comment statements.

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (establishes warnings and rule that counsel invocation ends interrogation)
Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) (once counsel requested, questioning must cease until counsel is present or suspect reinitiates)
State v. Alston, 204 N.J. 614 (N.J. 2011) (NJ approach: ambiguous references to counsel interpreted favorably to defendant; clarification allowed but advice is forbidden)
State v. Messino, 378 N.J. Super. 559 (App. Div. 2005) (distinguishes questions seeking advice from invocations of right to counsel)
State v. P.Z., 152 N.J. 86 (N.J. 1997) (totality of circumstances governs voluntariness beyond Miranda)
State v. Bey, 112 N.J. 123 (N.J. 1988) (State must prove admissibility of confession beyond a reasonable doubt under NJ law)
Maglio v. Jago, 580 F.2d 202 (6th Cir. 1978) (federal appellate decision treating "Maybe I should have an attorney" as invocation)