People v. Beltran

Defendant was convicted, after jury trial, of first degree murder of her five-year-old daughter. Court properly admitted statements Defendant made while in hospital, as mode and method of questioning indicated she was not in custody, and indicia of formal arrest procedure, such as handcuffs and fingerprinting, were absent. Although prosecutor's repeated reference, in closing argument, that victim was "a heavenly angel" were improper, Defendant was not prejudiced by comments; State had shown video in which Defendant admitted killing victim, corroborated by witness' testimony that he saw her brutally beat victim. (ZENOFF and BURKE, concurring.)