State v. Knight

In State v. Knight, 145 N.J. 233, 250-51, 678 A.2d 642 (1996), the Court granted pipeline retroactivity to the rule previously announced in State v. Sanchez, 129 N.J. 261, 609 A.2d 400 (1992), that "post-indictment interrogation of defendant violated his right to counsel under Article 1, paragraph 10 of the New Jersey Constitution" requiring suppression of his confession, id. at 279, 609 A.2d 400 because the purpose of that exclusionary rule was also to enhance the reliability of confessions. Knight supra, 145 N.J. at 256-58, 678 A.2d 642. The determination of retroactive application is generally guided by three factors: "(1) the purpose of the rule and whether it would be furthered by a retroactive application; (2) the degree of reliance placed on the old rule by those who administered it; (3) the effect a retroactive application would have on the administration of justice." Id. at 251, 678 A.2d 642.