State v. Lazaro C.-D.

Summary

The court affirmed the defendant’s convictions, holding that his police-station statements were obtained during a noncustodial interview and therefore were not subject to Miranda warnings. It held that the victim’s statements to her mother were improperly admitted as spontaneous utterances, but that error was harmless, and it rejected challenges to limits on immigration-related expert testimony and to nondisclosure of a detective’s personnel-file materials. The court concluded that the remaining evidence overwhelmingly supported the verdict.