State v. Terrell Hubbard (073539)
118 A.3d 314
| N.J. | 2015Background
- Police responded to a 9-1-1 call reporting an injured five-month-old girl, Lanaya Hubbard, who was in critical condition.
- Defendant Terrell Hubbard initially stated Lanaya was crying, lying on the bed, and he called for help after she stopped breathing.
- Hubbard was interviewed at the police station for about three hours without Miranda warnings; he was not handcuffed during the interview.
- Lanaya died three days later; medical findings showed healing bruises/fractures, brain swelling, and traumatic injuries suggesting abuse.
- A suppression motion challenged the October 20, 2008 statement as obtained during custodial interrogation without Miranda warnings; the trial court suppressed it.
- Appellate Division reversed, conducting de novo review of the videotaped interrogation per Diaz-Bridges; State sought Supreme Court review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| What standard governs appellate review of trial court findings when a videotape is involved? | State argues Diaz-Bridges limits deference; appellate can review videotape and make its own findings. | Hubbard argues appellate should defer to trial-court findings supported by the record. | Deference applies to trial findings; appellate may review video but must defer where evidence supports trial findings. |
| Was Hubbard in custody during the October 20, 2008 interview requiring Miranda warnings? | State contends the interview was investigatory; Hubbard was not in custody. | Hubbard contends the interview was custodial given the police environment and investigative pressure. | The interview was custodial; Miranda warnings were required and the statement must be suppressed. |
| Did the appellate panel properly limit its review to the videotaped statement or rely on other evidence? | State argues the trial court relied largely on videotape and related testimony; de novo review appropriate. | Hubbard contends the panel failed to defer to trial-court findings based on the full record. | The trial court findings, supported by the full record, must be given deference; de novo review was improper. |
| Does the statute and case law permit suppression when custodial interrogation occurred without Miranda warnings? | State asserts no custodial interrogation or Miranda violation; statements were voluntary. | Hubbard argues warnings were required due to custodial interrogation and involuntariness without warnings. | Miranda warnings were required; the statement was properly suppressed. |
Key Cases Cited
- State v. Gamble, 218 N.J. 412 (N.J. 2014) (deference to trial court factual findings in suppression appeals)
- State v. Elders, 192 N.J. 224 (N.J. 2007) (deference to trial court findings; videotape considerations)
- State v. Locurto, 157 N.J. 463 (N.J. 1999) (deference to credibility and factual findings; evidentiary record review)
- State v. Johnson, 42 N.J. 146 (N.J. 1964) (deference to trial court observations in fact-finding)
- Diaz-Bridges, 208 N.J. 544 (N.J. 2012) (limits de novo review when videotape is the sole basis for findings)
- Beheler, 463 U.S. 1121 (U.S. 1983) (Miranda warnings not required solely by presence in station house)
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (requirement of warnings during custodial interrogation)
- P.Z., 152 N.J. 86 (N.J. 1997) (custody and interrogation analysis; objective factors)
- Timmendequas, 161 N.J. 515 (N.J. 1999) (investigative questioning vs custody; objective analysis)
- O’Neill, 193 N.J. 148 (N.J. 2007) (custodial interrogation standards in New Jersey)