People v. Paulman

In People v. Paulman (5 NY3d 122, 833 NE2d 239, 800 NYS2d 96 [2005]), the Court stated that in order "to determine whether there is a 'single continuous chain of events' under Chapple, New York courts have considered a number of factors, including the time differential between the Miranda violation and the subsequent admission; whether the same police personnel were present and involved in eliciting each statement; whether there was a change in the location or nature of the interrogation; the circumstances surrounding the Miranda violation, such as the extent of the improper questioning; and whether, prior to the Miranda violation, defendant had indicated a willingness to speak to police. No one factor is determinative and each case must be viewed on its unique facts. The purpose of the inquiry is to assess where there was a sufficiently 'definite, pronounced break in the interrogation' to dissipate the taint from the Miranda violation. If so, the Mirandized statement is admissible at trial despite the prior, unwarned statement" (5 NY3d at 130-131).