State v. Carl Hreha (070222), 217 N.J. 368

Hreha was questioned about a September 11, 2006 incident at the OAG after IT staff discovered a phony MAC address and a single IP address traced to the printing of racist material.
During custodial interrogation on October 13, 2006, Dias and others questioned Hreha; Miranda warnings were read and he signed the card, with differing accounts about whether a waiver was explained in writing.
Hreha confessed to composing and sending the offending document; he later claimed promises of leniency (including PTI admission, avoiding jail, and not losing his job) induced the confession.
At the Miranda hearing, the trial court credited Dias’s testimony that no promises were made and denied suppression; the jury convicted on both counts.
The Appellate Division reversed, finding insufficient proof that Hreha voluntarily waived Miranda rights and that the statements should be suppressed.
The New Jersey Supreme Court reversed in part, remanding for a new Miranda hearing due to the trial court’s misapprehension of witness testimony and the need to re-evaluate promises of leniency under totality-of-the-circumstances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Were leniency promises made to induce the confession?	State argues no confirmed promises were made and waiver was voluntary.	Hreha contends officers promised leniency (e.g., PTI, lighter sentence, release without handcuffs) to induce confession.	Remand for a new Miranda hearing to resolve credibility and weight.
Is the Miranda waiver voluntary under totality-of-the-circumstances?	Waiver was voluntary beyond reasonable doubt; credibility supports voluntariness.	Promises of leniency undermine voluntariness; record insufficient to prove waiver.	Remand for fresh credibility findings; cannot determine weight of leniency promises now.
What is the appropriate standard of review for appraisals of trial court credibility on suppression issues?	Defer to trial court’s credibility findings unless clearly mistaken.	The record requires independent assessment when credibility is central to voluntariness.	Appellate court should defer but may reweigh upon remand; issues remanded for new findings.

Miranda v. Arizona, 384 U.S. 436 (Supreme Court) (mandatory warnings and voluntary waiver principles)
State v. Elders, 192 N.J. 224 (2007) (deferral to trial court on credibility/ factual findings; sufficiency review)
State v. Johnson, 42 N.J. 146 (1964) (special deference to trial court in credibility determinations)
State v. Galloway, 133 N.J. 631 (1993) (totality-of-the-circumstances test for voluntariness)
State v. Timmendequas, 161 N.J. 515 (1999) (factors in totality-of-the-circumstances analysis)
State v. Pillar, 359 N.J. Super. 249 (App. Div. 2003) (leniency promises as a factor in voluntariness analysis)
State v. Fletcher, 380 N.J. Super. 80 (App. Div. 2005) (promises of leniency may render confessions involuntary)