the invocation of the right to counsel entails terminating all questioning “until counsel has been made available [or] unless the accused [ ] initiates further communication, exchanges, or conversations with the police.” Edwards, supra, 451 U.S. at 484-85, 101 S.Ct. at 1885, 68 L.Ed.2d at 386. If an accused does initiate a conversation after invoking his rights, that conversation may be admissible if the initiation constitutes a knowing, intelligent, and voluntary waiver of the accused’s rights. Miranda, supra, 384 U.S. at 444, 86 S.Ct. at 1612, 16 L.Ed.2d at 707. The State bears a “heavy burden” of demonstrating that the waiver was knowing, intelligent, and voluntary. Hartley, supra, 103 N.J. at 260, 511 A.2d 80; see also State v. Galloway, 133 N.J. 631, 654, 628 A.2d 735 (1993) (<HOLDING>). C. The first question is whether defendant’s
holding that the state must prove juvenile delinquency beyond a reasonable doubt holding the determination of the voluntariness of a confession is a determination uninfluenced by the truth or falsity of the confession holding state must prove voluntariness of confession beyond a reasonable doubt holding that territorial jurisdiction must be proven beyond a reasonable doubt holding that failure of trial court to instruct jury that state must prove beyond reasonable doubt killing was not committed in heat of passion required reversal of murder conviction even though there was general charge that state was required to prove each element of offenses beyond reasonable doubt