STATE OF NEW JERSEY VS. RYAN L. HODGE
In this appeal, we granted leave to the State to consider the trial court's interlocutory order suppressing a statement taken from defendant, a juvenile at the time, shortly after his arrest for murder. Neither an attorney nor defendant's legal guardian were present at the time the statement was taken. Nor had defendant had the opportunity to consult with an attorney in advance of providing the statement. The motion judge accorded
pipeline retroactivity to State in the Interest of P.M.P., 200 N.J. 166 (2009). We reverse and hold that P.M.P. is to be applied prospectively.
P.M.P. announced a new rule; its purpose is not furthered by retroactive application; law enforcement officials, in good faith, have relied upon the old rule in conducting custodial
interrogations of juveniles; and retroactive application would have a significant impact upon the administration of justice. 05-15-12