People v Jackson

Holding The court held that while the defendant’s pre-Miranda statements in the holding cell were voluntary and spontaneous, the subsequent videotaped interrogation should have been suppressed because the initial pre-Miranda questioning constituted interrogation without a sufficient break. However, the error in admitting the videotaped interrogation was deemed harmless because the remaining evidence of guilt was overwhelming.

The court’s words

the pre-Miranda questioning "was not mere 'small talk,' but, rather, interrogation"

2026 NY Slip Op 06139, at the official text

the evidence of the defendant's guilt without reference to the erroneously admitted statements was overwhelming

2026 NY Slip Op 06139, at the official text

an intoxicated person can form the requisite criminal intent to commit a crime

2026 NY Slip Op 06139, at the official text