State v. Alvarez

In State v. Alvarez, 210 Ariz. 24, 26, P3, 210 Ariz. 24, 107 P.3d 350, 352 (App. 2005), a police officer found the victim of a brutal beating staggering down a road. The victim collapsed and began to slip in and out of consciousness. Id. The officer questioned the victim about his injuries to obtain medical assistance for him. Id. The officer was able to learn the victim's first name and, before the victim lost consciousness, that three men had jumped him and taken his car. Id. The court found that although the victim had made his statements in response to police questioning, the exchange did not constitute a police interrogation. Id. at 29-30, P21, 107 P.3d at 355-56. Under these circumstances, the questioning was "neither structured nor conducted for the purpose of 'producing evidence in anticipation of a potential criminal prosecution.'" Id. at 30, P21, 107 P.3d at 356.