M.P., a juvenile, is charged with gun possession and participation in a murder. He appeals the trial judge's decision to admit the statement he gave to detectives during a stationhouse interrogation, which was attended by his mother. M.P. asks the court to adopt a new categorical rule that would prohibit police from conducting a stationhouse interrogation of a juvenile unless the minor has consulted with an attorney. M.P. relies on neuroscience and behavioral science research that shows juveniles are not only more impulsive and compliant than adults but also tend to lack the cognitive skills to comprehend Miranda rights. He contends that in view of advances in the scientific understanding of adolescent brain development, no juvenile should be subjected to a stationhouse interrogation—with or without parental participation—until the juvenile has consulted with counsel.
The court explains it has no authority to pronounce any such per se requirement. While acknowledging there have been significant reforms to New Jersey's juvenile justice system in recent years based on scientific research on how a juvenile's brain develops and how it functions differently from a fully mature adult brain, the court holds those studies do not grant it authority to substantially rework the State's juvenile interrogation jurisprudence, and certainly not to overturn New Jersey Supreme Court precedents. The court concludes that while the rules and principles announced in those precedents are not immutable, it is for our Supreme Court and the Legislature—not an intermediate appellate court—to weigh the benefits and costs of the major juvenile justice system policy shift M.P. proposes.
The court also declines M.P.'s request to revise the Miranda warnings to make them more comprehensible to adolescents. While noting the current warnings are not sacrosanct and might be improved based on juvenile brain research, the court concludes the task of revising the warnings to address the inherent differences between adults and juveniles would benefit from a collaborative process the court cannot provide.
Turning to the application of existing precedents to the present case, although the court is mindful of the deference it owes to the trial judge's factual findings, it concludes that considering all relevant circumstances, including M.P.'s intellectual challenges, mental conditions, highly emotional state, and the role his mother played, the State failed to prove beyond a reasonable doubt that M.P. knowingly, intelligently, and voluntarily waived his right against self-incrimination. The court therefore reverses the trial judge's decision.
The court rejects the State's argument that reviewing courts should not consider an interrogee's personal characteristics, such as intelligence and education background, if those circumstances were not known by or "noticeable" to police. The court holds those circumstances remain relevant notwithstanding they may not manifest outwardly during an interrogation. The court explains that reviewing courts do not employ a purely objective test when determining whether the State proved a valid Miranda waiver beyond a reasonable doubt, but rather consider the characteristics of the accused and not just the details of the interrogation.
The court also rules the guidance the Supreme Court provided in State in Int. of A.A., 240 N.J. 341, 354 (2020)—which held police should provide an opportunity for a juvenile and parent to consult privately after Mirandawarnings are given—did not mandate a new rule of police procedure but rather amplified the existing totality-of-the-circumstances test. Accordingly, the court reasons the rationale undergirding A.A. should be given retroactive effect.
