State v. Lazaro C.-D.

Summary

The court affirmed the defendant’s convictions, holding that his voluntary, nonhostile police-station interview was not custodial for Miranda purposes, so his statements were admissible without warnings. It held that the victim’s statements to her mother were improperly admitted as spontaneous utterances because the state did not establish continuing stress, but the error was harmless in light of the defendant’s admissions and recorded confession. The court also upheld limits on defense expert testimony about the U visa process and found no discoverable impeachment material in the detective’s personnel file.