On Feb. 8, 2022, the New Jersey Supreme Court held that defendant's Miranda waiver, based upon a police lie about alleged incriminating evidence, could not be voluntary, and therefore her confession must be suppressed. State v. Gonzalez, 249 N.J. 612 (2022).

While defendant was employed as a nanny, one of the children she was caring for, Tommy, was diagnosed as having three fractured leg bones. Defendant, after signing a Miranda waiver form, initially denied responsibility for Tommy's injuries.