An off-hand comment that a suspect made to a state trooper—and that the trooper later realized reflected the suspect’s knowledge of a crime—was a spontaneous utterance that did not require that Miranda rights be given, a court concluded.
Nothing in the record indicated that Francis Ero’s statement resulted from any “inducement, provocation, interrogation or its functional equivalent,” an Appellate Division, Third Department, panel decided in People v. Ero, 106634.
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