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PEOPLE v. SANTIAGO
Appellate Division of the Supreme Court of New York, First Department.
Oct 7, 2010
The court properly denied defendant's motion to suppress his statement. The hearing evidence establishes that the officer's question, "What happened?" at the scene of an assault did not constitute custodial interrogation requiring Miranda warnings ( see People v Taylor, 57 AD3d 327, lv denied 12 NY3d 860).
Defendant's remaining contentions are unavailing ( see People v Correa, 15 NY3d 213).
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