State v. Yohnnson, 204 N.J. 43

Defendant Yohnnson was arrested on outstanding warrants and interrogated about robberies; initial Miranda warnings at scene were incomplete.
Detectives believed warnings were proper and did not re-administer rights at the police station; the first interview lasted roughly 2.5 hours with little incriminating detail.
During a cigarette break with a smoker officer, defendant recommenced dialogue after a remark about counsel; full warnings were then administered and he confessed.
Trial court found warnings were properly given and waiver voluntary; Appellate Division remanded, citing ambiguity about scrupulous honoring of rights during the break.
Appellate Division concluded the interrogation resembled a “question-first, warn-later” scenario under O’Neill and suppressed the confession; this Court granted certiorari.
Supreme Court reversed, reinstating the trial court’s denial of suppression and the conviction, holding the circumstances did not constitute improper application of O’Neill.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Which framework governs voluntariness here	State argues O'Neill does not control; apply totality analysis.	Yohnnson argues O'Neill framework applies to two-step interrogations.	O'Neill framework not required; totality of circumstances governs
Scrupulous honoring of right to counsel	State contends rights were honored; no coercive pressure.	Yohnnson contends pre-warning questioning and pre-break conduct undermined rights.	Rights scrupulously honored; no improper interrogation after invocation
Knowing, voluntary, intelligent waiver	Waiver was voluntary after full warnings; credibility favors state.	Yohnnson asserts lack of proper warnings taints waiver.	Waiver was knowing, voluntary, and intelligent
Effect of cigarette-break conduct	Break was routine; did not constitute interrogation or coercive influence.	Break discussion manipulated defendant to confess.	Cigarette break not interrogation; no requirement to re-warn
Overall admissibility of confession	Combined factors support admissibility under totality of the circumstances.	Appellate Division correct in suppressing under O'Neill analysis.	Confession admissible; suppression reversed

State v. O'Neill, 193 N.J. 148 (2007) (five-factor framework for two-step interrogations)
Michigan v. Mosley, 423 U.S. 96 (1975) (scrupulous handling of rights after prior questioning)
Oregon v. Elstad, 470 U.S. 298 (1985) (initial unwarned statement; downstream warned confession admissibility)
Missouri v. Seibert, 542 U.S. 600 (2004) (two-step interrogation and policy concerns)
State v. Bey (I), 112 N.J. 45 (1988) (Mosley-type protections and scrupulous honoring of rights)
State v. Nyhammer, 197 N.J. 383 (2009) (totality of the circumstances for pre-custodial waivers)