State V. Ritt

Twenty-three-month-old Hannah Ritt died in her crib when a fire occurred in her home on March 25, 1997. Death was caused by toxic fumes released from the burning of an acrylic afghan. Six days later Hannah's mother, appellant Kelly Jean Ritt, spoke with Detective James Rgnonti of the Hastings Police Department and admitted tossing an afghan from Hannah's crib toward a daybed in the room and not moving it when it landed partially on a space heater on the floor. Ritt denied "wanting" to cause a fire or kill Hannah but admitted "hoping" that Hannah would die. Ritt was arrested and subsequently indicted on two counts of first-degree murder, *fn1 two counts of second-degree murder, *fn2 one count of third-degree murder *fn3, one count of second-degree manslaughter, *fn4 and one count of first-degree arson. *fn5 She was convicted of all charges except manslaughter following a month-long jury trial in Dakota County in which 48 witnesses testified. Ritt asserts three issues on appeal: (1) that her statement to Rgnonti was involuntary and inadmissible because she was subjected to "psychological interrogation"; (2) that the trial court erred in excluding expert testimony describing police interrogation practices; and (3) that the trial court erred in admitting a videotaped "test burn" involving an afghan and a space heater similar to those involved in the fire in Hannah's room. We affirm Ritt's conviction.