New Jersey v. Erazo
Annotate this CaseDefendant Andreas Erazo was convicted for the 2017 rape and murder of eleven-year-old A.S. The Appellate Division found that defendant’s confession, obtained during a second interview, five hours after his initial 90-minute interview, was not knowing, intelligent and voluntary, and should have been suppressed. The New Jersey Supreme Court reversed, finding defendant was not in custody at the time of the pre-confession interview, thus Miranda was not implicated. The Supreme Court also found that the detectives’ tactics during the Mirandized interrogation were not coercive, did not minimize the Miranda warnings, and were consistent with New Jersey v. Sims, 250 N.J. 189 (2022). Thus, under the totality of the circumstances, defendant’s Miranda waiver was knowing, intelligent, and voluntary, and the trial court properly denied his motion to suppress.
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