In State v. Zakariyya Ahmad, decided June 15, the New Jersey Supreme Court considered the admissibility of a statement given by a 17-year-old defendant who was discharged from a hospital emergency room after being treated for a gunshot wound. He was placed in a police car and taken to police headquarters after which his father was directed to take him to the county prosecutor’s office where he was asked about the shooting death of a café owner earlier that day. After a further investigation by the police, including watching surveillance video of the cafe and reviewing forensic evidence, defendant became a suspect of the crimes committed. The trial court admitted defendant’s statement to the police on the basis that he was questioned before being deemed a suspect in the shooting death.

The Appellate Division affirmed defendant’s convictions on the ground that he was interviewed during an investigation and not subjected to “custodial interrogation” and, therefore, Miranda warnings did not have to be given and a voluntary waiver of rights obtained before his statement was taken and admitted into evidence against him at trial.