State v. Dabate

Summary

The court affirmed the defendant’s convictions for murder, tampering with or fabricating physical evidence, and making a false statement. It identified four prosecutorial improprieties but held that, individually and cumulatively, they did not render the trial fundamentally unfair or create a reasonable likelihood of a different verdict; it also rejected the supervisory-authority request, upheld admission of the Fitbit evidence, and upheld denial of suppression of the defendant’s hospital statements. The court concluded that the hospital interview was noncustodial for Miranda purposes.