Hof v. State

MOYLAN, Judge.

This appeal poses a most basic question: Does there even exist such a thing as a law of confessions? Or is it the case that there are, rather, many laws of confessions? Be the law of confessions single or multiple, the burden is, in any event, indisputably on the State to satisfy the trial judge in the first instance that a challenged confession is admissible. It is a legitimate and increasingly popular defense strategy to exploit that allocation of the burden by constructing as arduous an obstacle course as possible for the State to negotiate.

In pursuit of that strategy, the…