10-7 >> Car four, caller just came called back and said that the driver bumped over the wheel. >> Okay. Lock, is that door open? [ __ ] All right. Ma'am. >> What began as a medical emergency on the 8th of February 2023 quietly unfolded into a textbook case across three areas of law. The first question the footage raises is constitutional. Can an officer enter a locked vehicle without a warrant? The answer lies in the emergency aid doctrine established in Brigham City versus Stuart 2006 which permits warrantless entry when there is an objectively reasonable belief that an occupant faces serious injury or death, that standard was clearly met here. It is worth noting what this doctrine is not. It is not a general exception to the Fourth Amendment's warrant requirement. The emergency must be genuine and ongoing. Once the immediate threat is resolved, the authority to act without a warrant ends with it. >> How do. >> Ma'am. >> You okay? You okay? Miss. Can you speak? >> Yes. >> Okay. What's going on? Are you hurt? She might be having a seizure. She's really She's really tense right now. >> Look like she had a seizure earlier. Can you uh get the seat lower? Can you lower your >> I got it. I got it. >> What's her name? Angela what? Yeah, she's okay. She's breathing. She's not moving well. No, she's up. Very tense. I don't think she can move. Yes. >> What's her name? >> Who are you, sir? >> What What What's her name? Angela. Who are you to Angela? >> No, she's up but she I can't like remove her. Her muscles are all super tense right now. Ma'am, I'm bleeding. I don't want to get that on you. You keep leaning over me. You're okay. I know you're trying to help here. I got it. Yeah. >> Like I Like at first I didn't see nobody. And then I like seen her like shake her like >> No. Can we get EMS? We dispatched them already? See if she's got any paperwork in there with insurance, anything like that so we can Angela. Angela. Somebody get an Narcan. Thanks. >> This isn't typical for someone that's overdosing. That's why I'm asking you if she's on medical issues. >> Yeah. >> Once the subject regained consciousness, the inquiry shifted, and so did the legal obligation. Before any questioning could begin, Miranda v. Arizona, 1966, required the officer to advise four elements: the right to silence, that statements may be used in court, the right to an attorney, and the right to appointed counsel if needed. The officer delivered all four before asking a single substantive question. That sequence matters. The Fifth Amendment shields individuals from compelled self-incrimination, not from voluntary admissions. What many people do not realize is that Miranda warnings alone do not end the interrogation. Under Burgess v. Tompkins, 2010, a suspect who receives Miranda warnings and then speaks voluntarily is deemed to have waived those rights without a written signature required. When the subject disclosed heroin and crack cocaine use without coercion, that statement became constitutionally admissible. As the court held in California v. Prysock, 1981, Miranda warnings need not follow a script, they must only be substantively complete. >> You're bleeding, Chris. >> I know, I had to break the window. No, [clears throat] he's saying she uses it herself, so she's just got one Narcan. Yeah, if somebody Yeah, if you can I got it. Just don't put her down on the glass. Get under her arms if you can. Thanks. Keep your legs out of your back. Get her on her side if you can. Head down. Slow, slow, slow. Head, head, head. All right. What's her name? >> Jessica. >> Angela. >> Angela, wake up. >> Sir, you wake up? On the phone, sir. Does she use? What does she use? Okay. Snort inject, do we know? No? I don't We got a call she crashed into a fence. She was slumped over the wheel when I got here. She's out of the car now. Yes. What's that? No. What's What's What's her last name? Camperella. You got a light, bro? >> Yeah, we got it. Thank you. >> I'm trying to see if there's a bag here or anything. They're working on her. They're working on her, sir. She's She's got a pulse. She's alive. All right, sir. What's your name? >> Angela. >> I mean, I'm sitting here on the phone with you. I I could stop giving you information if I don't know who you are. Yeah, she will go into Bay Shore. >> Angela, can you hear me? >> Her eyes are blinking now. She's just >> Okay. >> Do we know what her name is or is >> Angela Camporelli. Camporella, Camporelli. >> All right. >> Trying to see if I can find a license or something, but >> Hi. She's answering me. Angela? What happened? >> She was like this, the door was locked. I couldn't get to her, so I used the window punch on my knife, blew the back window out, and got in that way. But >> You got who's on the phone? Her husband or something? >> Somebody named Edwood. I don't know. I just hung up on him. I was done giving him anything. Told me she's all right. She should be going to the hospital. >> With the admission secured, the investigation moved to the field. The NHTSA 3 test battery HGN, walk and turn, one leg stand, is the validated standard for detecting CNS impairment. Two or more clues on the walk and turn alone indicate impairment at 79% accuracy. The HGN test carries particular weight in opioid cases. Heroin suppresses the central nervous system, producing distinct nystagmus and involuntary jerking of the eye at maximum deviation and prior to 45°. That response cannot be faked or consciously controlled. Critically, officers screened for disqualifying medical conditions before each test. Omitting that step can render FST results inadmissible. Under NJSA 39:4-50, DWI is not limited to alcohol. It extends to any narcotic that impairs the ability to drive safely. Taken together, the post-Miranda admission and FST performance established probable cause for arrest. The charge was legally grounded. Probable cause, as the Supreme Court defined in Illinois versus Gates, 1983, requires a fair probability that a crime has been committed, not certainty, not proof beyond reasonable doubt. The totality of circumstances here satisfied that standard without ambiguity. >> Did she say she has like medical issues or anything? >> No, I actually like I was asking like cuz the one lady thought she was having a seizure. So I was like, "Okay, maybe they know where I didn't know." >> She like just tense to control it. >> Super tense, yeah. And I didn't want to do it alone but we're on the glass, you know. >> You know, or hurt people. >> But she was She was talking to me at first. When I first got here, she was talking to me. >> Yeah, no, they're good. They were just at this point before but now they're good. >> Like she told me what her name was. She told me she was Angela. >> Yeah. >> She probably had out for a tow also. >> Yeah, I did. >> You did? >> The orange auto body shop is fine. >> Good. >> Hey Hunter, where do you guys got like alcohol wipes? >> What's that? >> You got alcohol wipes in there? >> Yeah, yeah. >> Whereabouts? Where am I looking? >> She's got you. >> All right, she's got me. I'm not even sure if they're little cuts or if glass shards. >> Would you punch it? >> No, I had a window punch on my knife. So, it just when it blew out it shot up caught me a little bit. Yeah, I had to break her window. Yeah, clean this [ __ ] up real quick. Yeah, it's just I'm not really worried about it. Just wanted to clean it, make sure there's no glass stuck in my hand. >> No. If even if there is one you would get home or whatever, take some shaving cream and put it over it and just wash your hands like it's soap. >> All right. >> That'll help get uh any glass shards out. >> Let me see that. Thank you. Never do that before. >> You got glass in there? >> I don't know. That's what I was worried about, but we're good. >> You just punched it? >> No, I have a window punch on my knife, yeah. >> Okay. Ever done that before, though? No. On that side the glove box is pretty blown out. See the airbags, so. I'm good. Yeah, it was just the glass when it shattered just shot out and cut me up a little bit. Now, the guy on the phone said she uses dope. >> Is it this thing? >> Yeah. I used just a [ __ ] small knife, so my hand was still right at the window when it >> Busted over? >> Yeah. Not bad. >> So now I know not to use my knife to do that. >> I was My ass was in the car. I thought about it and then I remembered my knife has it, so I went for it. >> Mostly the baton doesn't work. >> No. >> It just bounced right back at you. >> Anyway, it took me a while, I think three shots with that cuz I thought it was going to go real easy. So I went a little harder. >> The window's like anti >> See if you can get to the fence. Yeah, a little bit. Hardly. All right, forgot >> So she's demanding that she comes out here. She wants to go back to her car. She doesn't want to go to the hospital. She wants to go home. Uh she said that she didn't take anything. To her knowledge all of her info, her license, registration, insurance should be in there. >> Let us see these real quick. >> Hey. Yeah. >> All right. But she wants to talk to you guys. She doesn't want to go. >> All right, you want to just shut up? Are you a FST certified? >> Yeah. >> Okay. >> I'm fine. >> Good. So you don't want to go to the hospital? >> No. >> All right. Well, listen then. If you If you're going to demand a release, that's fine. You got to sign a couple waivers. Then you're going to come out and we're going to put you through some tests and stuff. Okay? All right. So, we'll just work with these guys whatever they need you to do for a couple minutes and let's Does she already >> No, not yet. Her ID. >> I don't. Where is your license? >> It's in my bag. >> All right. Can you just give her your information as >> I'm just going to grab that. >> I'll get it for you, sure. Just where It's in your bag in the car? >> Yeah. >> Okay. I'll get you your whole bag. She's pretty uh She's pretty adamant she wants her bag. So, she's She's hiding something. I don't know if we're I'm saying it's her license in here. Yeah, I don't give her the whole bag. Just give her her ID. That's what they're looking for. Hey, Ryan. Did you check this uh bag here? >> Yeah, I mean I I went through it. I didn't go through >> Like we said, this is probably what we're looking for. Insurance is in the center console. >> Wait, I have the I have the insurance. >> He said she's like very adamant that she wants her bag. >> Yeah. I think so. All right. >> So, right now she's she's in our car. >> first and then search the car. >> All right. They need her info though and she's >> Yeah, it's on the front of the car. So, he's got it. >> He's got her ID? >> Yeah. >> Okay, perfect. Got the license? >> What do you want? >> Just her license. Sorry. >> Thank you. >> No problem. Uh I have it in the car. >> You said it's in the front seat? >> Yeah. Who's 15? >> Oh, that was ours. Who does ours is here first style. You need that. Okay. I'll throw it in here. Yeah, all you really need all I ever take I take this and I just throw it in my pocket. That's all you need. Because it's got the lot number on it. No, I don't know. Did you guys carry two of these? Okay. Okay, yeah, yeah. She actually was mine I was like I don't think I grabbed mine. I just jumped out of the You took the Narcan out. The back of it though. Yeah, the things that they're we're not keeping. What's that? Think about it. It's fine. All right, Andrew, can you step over here for us? So, listen boy, ask any questions do anything like that I just want to read those to you, okay? Just This way I don't want you to go and incriminate yourself or anything like that, all right? So, you have the right to remain silent. You have the right um you have the right to remain silent. Anything I say to you can and will be used against you in a court of law. If uh you have the right to an attorney you cannot afford an attorney one will be appointed to you. Do you understand these? Have I explained this to you? Okay. So, what happened here tonight? How do we get here? I just turned around and I was all over the place. You had to turn around? So, which way were you coming from this way obviously? So, you got up here and tried to turn and just jumped the curb? I don't remember. You don't remember? Okay, is there a reason you don't remember? Did you use anything tonight that you maybe shouldn't have? Yeah. So, what were you using? I used heroin. You were using you were using heroin crack? Crack. Any alcohol? No alcohol. All right. So, still going to run you through a series of these tests out here, okay? So, at any time you can terminate, refuse to take these tests, but otherwise, uh, we're just going to have you go through it, okay? You got a, uh, flashlight on you? >> The left side one? >> No, this one works. >> That this one? >> Yeah. All right, so before this accident, have you had any like head injuries or anything like that? >> No. >> No, okay. Cuz this first test we're going to do is, uh, with your eyes. It's an HGN test. It's all about the tracking of your eyes. So, a head injury might alter that. So, no head injuries except for something maybe sustained in this car accident, correct? All right. So, see this see this pen? See the tip of this pen? >> Yeah. >> What color is it? >> Black. >> Black? All right. You're capable of following this pen as I move it? >> Yeah. >> All right. So, that's what I want you to do. Want you to put your hands down at your side, feet together, and using just your eyes and only your eyes, I want you to follow this the tip of this pen wherever it goes, all right? Don't turn your head, just your eyes. Do you understand these instructions? All right. All right, and keep following now. All right, again, just keep following this pen with just your eyes. You're doing good. >> All right, you can relax on that test. All right, next test is going to be a walk and turn test. All right? So, what I'm going to need you to do is going to be easier if you step here next to this officer. Turn around, face me. So, I'm going to explain the instructions to you. While I'm explaining the instructions, I want you to wait in the ready position. Um before we start this, do you have any leg injuries, anything like that? No again, you said no head injuries before, right? Nothing No reason you shouldn't be able to keep your balance. Okay. So, in the ready position, I want you to go right foot in front of your left, hands down at your side. I want you to remain in this position while I explain the instructions to you, okay? As I explain the instructions, just do your best, you know, if you have to re-gather, re-gather, but all right? So, what we're going to do is we're going to take nine heel-to-toe steps. You're not going to do it till I tell you to, though. All right? So, when you take these steps, I want your hands to remain at your sides. You're in this ready position. So, we're doing nine steps. So, your eyes are going to be down on your toes, you're going to walk in a straight line. Heel to toe, one, two, three, four, five, six, seven, and so on, all the way to nine. When you get to your ninth step, I want you to take a series of small steps to turn around. And give me nine steps back. One, two, three, four, five, and so on until you get to that ninth and final step, okay? With each step, I do want you to count the steps, all right? You explain these just understand these instructions how I'm explaining them? All right, you can begin. >> 1 2 3 4 5 6 7 8 9 Turn around. >> Series of small steps. Series of small steps now to turn around. Yep, leave your lead foot down. And take a series of small steps to turn around. You can pivot that front that foot. Yep, just like that. Okay? Now go back the other way. Count your steps out loud. >> 1 2 3 4 5 6 7 8 Go this way? >> Yep, you can That's the end of the test. The ninth step was the end, all right? All right. So, the third test and last test we're going to do now is going to be the one leg stand test. I have to ask again, no injuries, right? No reason you shouldn't be able to perform this test, right? All right, so I want you to wait, hands at your side. Feet down. I want you to lift your right foot up approximately 6 in off the ground. And I want you to look Point your toes out and look down at your toes. As you're doing that, I want you to count. Okay? 1 1,000, 2 1,000, 3 1,000. Keep going until I tell you to stop. All right? So, you understand these instructions? >> Yep. >> All right, you can begin. >> 1 1,000, 2 1,000, 3 1,000, 4 1,000, 5 1,000, 6 1,000, 7 1,000, 8 1,000, 9 1,000, 10 1,000, 11 1,000, 12 1,000, 13 1,000, 14 1,000, 15 1,000, 16 1,000, 17 1,000, 18 1,000, >> Okay. >> 19 1,000, >> Okay, you can stop. All right. So, that's That's it for our test here. Um with that being said though, you know, you did uh have a car crash, you know what I mean? You crashed into property with nobody else, no reason really for the crash. You admitted to me after being Mirandized that you did use tonight. All right, so you are going to come with us. We're going to bring you into police headquarters and you're going to, you know, be charged with driving under the influence, all right? Okay. >> Can you turn off the air supply back? >> The customer. >> I'll just probably leave it like that. >> Yeah, yeah, I got you. Not too tight on your wrist. You're okay? >> I'm fine. >> Listen, I'm only asking cuz the vehicle is going to be towed. There is going to be a tow truck operator who's going to come and have to get in your vehicle to move it onto the flatbed. Is there anything in there with any more of that stuff you were using tonight that, you know, we should maybe remove before he gets in there? >> No. >> All right. So, this officer is going to bring you to the back of the car. >> Good. Yes. >> They're on the desk. >> the desk. >> I got it. >> I just need your date of birth. >> 12 03 >> Officer Chris receives a B plus. The emergency entry was justified, Miranda was properly timed, and the FST battery was correctly administered. One deduction. The Miranda delivery stumbled mid-recitation. Legally sufficient under Price sock, but imperfect warnings invite suppression motions. Subject Camporeale receives a B minus. She complied and did not resist. However, her unprompted drug admission was constitutionally unnecessary. Had she invoked her right to silence immediately after Miranda, the prosecution's case would have rested on FST data alone, a weaker foundation. Three lessons emerge from this footage. First, exigent circumstances authorize emergency entry, but the justification must be camera documented. Second, Miranda timing is decisive. Any admission before advisement is suppressible under the exclusionary rule Mapp versus Ohio, 1961. Third, the right to silence survives Miranda. Post- warning silence cannot be used as evidence of guilt. Doyle v. Ohio, 1976. Invoking counsel ends all questioning immediately. Voluntary statements, once made, are admissible and very difficult to retract. 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