Guy Zappulla v. People of the State of New York

A five-justice panel of the New York State Supreme Court, Appellate Division, Second Department, ruled that Guy Zap-pulla’s signed confession to the murder of Jennifer Scarpati was inadmissible because the police failed to re-administer the warnings required by Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966). People v. Zappulla, 282 A.D.2d 696, 697, 724 N.Y.S.2d 433, 434 (2d Dep’t 2001).5 Those same judges, however, unanimously concluded that the error was harmless beyond a reasonable doubt because the remaining evidence of Zappulla’s *476guilt was overwhelming. See id. at…