State v. Michaels
New Jersey Supreme Court
642 A.2d 1372 (1994)
- Written by Eric Miller, JD
Facts
Margaret Kelly Michaels (defendant) worked at a nursery school, first as a teacher’s aide, then as a teacher. One of the preschool boys in Michaels’s care made comments to his mother indicating that he and two other boys were subject to disturbing acts of sexual abuse by Michaels. The boy’s mother contacted the state Division of Youth and Family Services, which in turn contacted the county prosecutor’s office. An investigation began, and Michaels was charged in connection with the alleged sexual abuse. Investigators with the state of New Jersey (the state) (plaintiff) conducted extensive questioning of Michaels and several of the children in her class, ages 3 to 5. The interrogations were characterized by leading questions, mild threats, cajoling, and positive and negative reinforcement to obtain certain responses. Some of the children were interviewed repeatedly over a period of nearly two years. The state’s case at trial relied heavily on statements obtained through those interviews. The jury returned guilty verdicts on numerous counts, including sexual assault and endangering the welfare of children. Michaels appealed. The appellate division reversed, holding that the interrogation procedures were improper. The state appealed. The New Jersey Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Handler, J.)
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