The following excerpt is from People v. Lanahan, 431 N.E.2d 624, 447 N.Y.S.2d 139, 55 N.Y.2d 711 (N.Y. 1981):
A defendant in custody who immediately admits his guilt when informed of the charge against him cannot be said to have been interrogated. When the police have also provided details of the underlying criminal act, an affirmed finding that the defendant's admission was spontaneous should be upheld, particularly when the defendant himself requested the additional information. To hold as a matter of law, as the majority now does, that such a statement is not spontaneous, because not literally "self-generating", unrealistically narrows to the point of extinction, the exception for spontaneous confessions which in the past has been one of the few consistently approved concepts in this otherwise volatile area of the law. It also ignores well-settled principles holding this type of question to be essentially a factual one beyond our review. Indeed it effectively overrules last year's decision in People v. Lynes, 49 N.Y.2d 286, 295, 425 N.Y.S.2d 295, 401 N.E.2d 405, in which we expressly rejected the notion that "any police remark, no matter how innocuous, would constitute an interrogation, as long as it was followed by an inculpatory statement."
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