Defendant also argues that the People failed to prove that his conduct caused the death of William Nietsch. However, even if the injuries inflicted by striking the child with the snowmobile had not caused his death outright, defendant's conduct in leaving the child unconscious and helpless in the middle of a highway in the dark of night during a blizzard was a sufficiently direct cause of death upon which to impose criminal liability (see, People v Kibbe, 35 N.Y.2d 407, 413, affd 431 U.S. 145; People v Weir, 112 A.D.2d 594, 595). We also find defendant's next contention, that he was denied a fair trial, unpersuasive even if all of the errors he has alleged are considered cumulatively.
There was no custodial interrogation of defendant by Jordan such that Miranda warnings were necessary. Custodial interrogation means questioning initiated by law enforcement officials after a person has been taken into custody or otherwise deprived of his freedom in any significant way (see, Miranda v. Arizona, 384 U.S. 436, 444). Here, Jordan was not required to advise defendant of his Miranda rights because there was no "custody" or "interrogation" (see, People v. Weir, 112 A.D.2d 594). We also conclude from the record that the real evidence was turned over to the police voluntarily by defendant.