State v. Armando Garcia, 140 A.3d 133

Background

Victim Brooke was found brutally murdered in her Pawtucket home on June 26, 2010; her toddler daughter was found alive. Blood, disorder in the house, missing phones, and a knife were observed at the scene.
Police initially arrested Brooke’s husband, Joe, but cleared him after corroboration of his alibi and searches. An anonymous tip (from defendant’s cousin) led police to Brooke’s missing car; blood in the car matched Brooke’s DNA.
Defendant Armando Garcia was arrested the next day; he had fresh injuries and bloodstains on his clothing. He gave multiple written statements and a videotaped confession at the police station admitting he beat and stabbed Brooke after an altercation.
Defendant moved to suppress his custodial statements, arguing they were involuntary and resulted from undue delay in presentment; he also challenged several evidentiary rulings and later moved for a new trial.
At trial the state presented the videotaped confession, handwritten statements, forensic evidence linking defendant to Brooke’s blood, and other circumstantial evidence; defendant testified and blamed Joe and claimed his confession was false and prompted by remorse.
Jury convicted Garcia of first-degree murder, failure to report a death, and operating a vehicle without consent; he was sentenced to life plus additional concurrent and consecutive terms. The Supreme Court affirmed.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Garcia)	Held
Admissibility of custodial confession	Confession was voluntary, knowing, intelligent; proper Miranda warnings given; waiver valid; any delay in presentment was waived by defendant	Confession involuntary due to assurances (no media), deprivation (food), cigarettes, and undue delay in presentment—therefore suppression required	Trial justice’s factual findings accepted; confession voluntary under totality; Rule 5(a) presentment delay waived by written agreement; no causative effect from delay; statements admissible
Rule 5(a) / prompt presentment	Delay did not taint confession because defendant waived presentment in writing and repeatedly requested delay	Detectives unduly influenced waiver by conditioning his staying at station on signing; delay caused confession	Waiver found knowing and voluntary (signed agreement, initialed clause denying promises); defendant requested to delay; no undue influence shown
Admission of testimony about burial dress (Joe’s testimony)	Testimony was relevant to identification/circumstances	Admission was irrelevant or prejudicial	Issue likely unpreserved; even if error, harmless beyond a reasonable doubt given overwhelming evidence (confession, DNA, injuries)
Admission of autopsy brain photograph	Photo was a limited, relevant visual aid to explain blunt-force trauma and cause of death	Photo was cumulative and inflammatory; intended to inflame jury	Trial justice did not abuse discretion: limited use, cropped, brief, aided jury understanding of medical examiner’s testimony; admissible
Motion for new trial (weight/credibility)	Verdict supported by weight of evidence; trial justice properly exercised thirteenth-juror function	Trial justice overlooked exculpatory evidence re: Joe’s motive/alibi and defendant’s lack of motive	Trial justice independently reviewed credibility and weight, found defendant not credible and confession truthful; denial of new trial affirmed

Key Cases Cited

State v. Humphrey, 715 A.2d 1265 (R.I. 1998) (two-step review for voluntariness of confessions; defer to factual findings, review voluntariness de novo)
State v. Amado, 424 A.2d 1057 (R.I. 1981) (confession involuntariness defined by coercion or improper inducement)
State v. Nardolillo, 698 A.2d 195 (R.I. 1997) (prompt presentment rule is prophylactic; suppression only if delay causally affected confession)
State v. Lionberg, 533 A.2d 1172 (R.I. 1987) (delay in presentment and causative effect standard for suppression)
State v. Brown, 88 A.3d 1101 (R.I. 2014) (trial-judge discretion on admission of autopsy photos; relevancy and prejudice balancing)
State v. Barros, 24 A.3d 1158 (R.I. 2011) (no constitutional right to electronic recording of custodial interrogation)
State v. Tassone, 749 A.2d 1112 (R.I. 2000) (autopsy/photo evidence may be gruesome but admissible when material and competent)
State v. Carter, 744 A.2d 839 (R.I. 2000) (autopsy photographs as visual aids to medical testimony)
State v. Robertson, 740 A.2d 330 (R.I. 1999) (harmless-error doctrine where overwhelming evidence supports conviction)
State v. Gregson, 113 A.3d 393 (R.I. 2015) (trial justice as thirteenth juror on new-trial motions; standards for overturning denial)