State v. Reynoso, 2026 N.J. Super. LEXIS 41 (N.J. Ct. App. 2026)

The New Jersey Superior Court Appellate Division held that the State failed to meet its burden of proving voluntariness of a youth’s Miranda waiver and reversed the trial court’s denial of defense’s suppression motion. Based on a totality-of-circumstances analysis, the court considered the following factors in making its decision: the youth’s Spanish-speaking mother was present during the interrogation but the questioning was conducted mostly in English without translation, which limited the youth’s mother’s ability to offer timely advice and the police improperly burdened the youth by telling him that speaking with a lawyer may change his circumstances on whether he will be charged and detained.

The court stated in relevant part: Balancing the factors constituting the “totality of the circumstances,” we conclude that the State has not met its burden of proving voluntariness beyond a reasonable doubt. The combination of factors militating to various degrees against voluntariness—the impairment of the parent’s ability to effectively perform an advisory role by reason of her limited English proficiency and the inadequate translation services provided to her; the failure to afford defendant and his mother an opportunity to consult privately following the administration of Miranda warnings; and the detective’s seeming misstatement as to whether defendant was free to walk out of the interrogation room and go home, considered in conjunction with the detective’s near-simultaneous comment that impliedly imposed a burden on defendant’s right to confer with counsel—are too much for the State to overcome when viewed through the lens of the proof-beyond-a-reasonable-doubt standard. That standard erects a formidable hurdle the State must vault. We are constrained to reverse the order denying defendant’s suppression motion, vacate his convictions, and remand for a new trial.