State v. Daniel Tejeda
171 A.3d 983
| R.I. | 2017Background
- On March 31, 2015, Ashley Masi was found dead with a zip tie around her neck; time of death ~5:56 p.m. and manner ruled homicide by asphyxia.
- Investigation of Masi’s Backpage ad and phone records identified frequent March 31 communications between Masi and (401) 442-3344, linked to Daniel Tejeda. Texts place that number at Masi’s address that afternoon.
- Tejeda was arrested April 28 on a federal warrant; officers seized a cell phone and later obtained buccal swab and two search warrants (May 4 for phone records and May 6 for his apartment). Zip ties and a BB gun/replica firearm were recovered from his residence; DNA testing showed a minor contributor consistent with Tejeda on the zip tie.
- Pretrial, Tejeda moved to suppress the phone seizure, the evidence from the May warrants, and statements made at the hospital; the trial justice denied most suppression requests but suppressed statements after Tejeda said, “I don’t want to make a statement.”
- A jury convicted Tejeda of first-degree murder; he was sentenced to life plus a consecutive 25-year non-parolable habitual-offender term. He appealed raising IAD delay, suppression rulings, admissibility of hospital statements, and excessive sentence.
Issues
| Issue | State's Argument | Tejeda's Argument | Held |
|---|---|---|---|
| Interstate Agreement on Detainers (180‑day rule) | IAD no longer applied after Tejeda’s federal term ended; state was ready to proceed and delays were due to defendant’s motions | Trial commenced after 180 days under IAD, so indictment should be dismissed | Affirmed: IAD rights expired when federal sentence ended; alternatively delays were defendant-caused, so no dismissal |
| Seizure of cell phone at arrest (warrantless search incident to arrest) | Cell phone lawfully seized from Tejeda’s pants as safety/search-incident-to-arrest; officer testimony credible | Cell phone was in backpack, not on person; seizure inconsistent with other officers’ testimony so should be suppressed | Affirmed: trial justice credited Det. Poncia’s account; no clear error in admitting phone |
| Validity of May 4 (phone records) and May 6 (residence) warrants / Franks challenge | Affidavits, viewed as whole, provided probable cause; alleged omissions/misstatements were not materially false nor outcome-determinative | Affidavits omitted or misstated material facts (other contacts, number of calls) and contained inaccuracies, so warrants invalid | Affirmed: trial justice found omissions/misstatements not material; probable cause remained within four corners of affidavits |
| Hospital statements and timing (Miranda/invocation) | Limited pre‑invocation statements (phone numbers, claim he was at hospital) admissible; everything after invoked silence suppressed | Statements about being at Rhode Island Hospital were given after invocation and/or mischaracterized and should be suppressed | Affirmed in part: trial justice suppressed post‑invocation material; defense failed to preserve an objection to specific content so appellate challenge waived |
| Habitual-offender 25‑year consecutive term | Sentence appropriate given brutal nature of crime and prior felonies; habitual-offender statute authorizes consecutive term | Additional 25‑year term is unnecessary and does not further statutory purpose | Affirmed: trial justice acted within statutory authority and relied on severity of conduct and past convictions |
Key Cases Cited
- State v. Werner, 831 A.2d 183 (R.I. 2003) (standard of review for IAD dismissal claims)
- Franks v. Delaware, 438 U.S. 154 (1978) (standards for challenging warrant affidavits for falsehoods/omissions)
- Arizona v. Gant, 556 U.S. 332 (2009) (limits on searches incident to arrest and scope of area within arrestee’s immediate control)
- Chimel v. California, 395 U.S. 752 (1969) (search-incident-to-arrest principle defining immediate control)
- Davis v. United States, 564 U.S. 229 (2011) (Fourth Amendment protection against unreasonable searches and seizures)
- State v. Byrne, 972 A.2d 633 (R.I. 2009) (probable-cause/warrant review standards; deference to magistrate)
- State v. Patino, 93 A.3d 40 (R.I. 2014) (Franks hearing standards and materiality inquiry)