In State v. Burris, 145 N.J. 509, 679 A.2d 121 (1996), the defendant was asked to come to police headquarters for questioning regarding the death of her mother. Id. at 514, 679 A.2d 121. Defendant was read her Miranda rights and upon continued questioning she gave a non-incriminating statement. Id. at 514-15, 679 A.2d 121. Defendant then asked for a lawyer and refused to answer any further questions. Id. at 515, 679 A.2d 121. Nevertheless, the police questioning continued. Ibid. After several hours of questioning, defendant finally did give a statement confessing to the crime of murder. Ibid. The statements given by defendant were admittedly taken in violation of her Miranda rights but were allowed by the trial court to be used to impeach defendant's credibility on cross-examination. Ibid. In affirming the trial court, the Burris Court first noted that the impeachment exception to the Miranda rule is "strictly limited to situations in which the suppressed statement is trustworthy and reliable in that it was given freely and voluntarily without compelling influences." Id. at 525, 679 A.2d 121. Next, the court explained that "The critical issue that must be addressed . . . centers on the meaning of voluntariness as an element of trustworthiness." Ibid.