State v. Goulet
2011 R.I. LEXIS 80
| R.I. | 2011Background
- Goulet killed his dog Sparky with a .22-caliber rifle on May 1, 2006 after an argument with a neighbor.
- Sparky belonged to Goulet's neighbor, Heidi Eklund, who reported the incident to police after hearing a gunshot.
- Police recovered Sparky's body from a shallow grave and found an illegal sawed-off shotgun on Goulet's property.
- One year later, Goulet was charged with malicious killing of an animal (G.L. 1956 § 4-1-5) and possession of a sawed-off shotgun (G.L. 1956 § 11-47-8(b)).
- Goulet moved to suppress the warrantless search and sought severance of counts; the trial court denied these motions.
- A jury convicted Goulet on both counts; he was sentenced to imprisonment and other penalties, and appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether joinder of counts was prejudicial under Rule 14 | Goulet argued severance necessary to present justification defense without prejudice. | Severance would prevent prejudice from combining two distinct charges. | No abuse of discretion; no real and substantial prejudice shown. |
| Whether the initial warrantless search of Goulet's property was valid under the Fourth Amendment | Evidence from the curbside/curtilage search should be admissible under exigent circumstances and plain-view. | Initial search violated the Fourth Amendment and tainted subsequent warrant. | Emergency doctrine and plain-view findings upheld; initial search permissible. |
| Whether evidence obtained from the subsequent warrant search was tainted by the prior unlawful search | Warrant evidence should be admissible if derived from properly obtained information. | Wong Sun doctrine taint should exclude fruits of the prior illegal search. | No taint; taint analysis rejected because initial search was proper. |
Key Cases Cited
- State v. Pereira, 973 A.2d 19 (R.I.2009) (prejudice balancing for Rule 14 severance)
- State v. Lassor, 555 A.2d 339 (R.I.1989) (prejudice standard for severance)
- State v. Sharbuno, 120 R.I. 714 (R.I.1978) (joinder and severance considerations)
- Duquette v. Godbout, 471 A.2d 1359 (R.I.1984) (emergency doctrine and medical-like exigency support)
- State v. Jennings, 461 A.2d 361 (R.I.1983) (foundational emergency/search exceptions)
- Wong Sun v. United States, 371 U.S. 471 (U.S. 1963) (poisonous-tree doctrine context)
- Portes, 840 A.2d 1131 (R.I.2004) (emergency/search exigency relevance to cursory searches)
- Minced v. Arizona, 437 U.S. 385 (U.S.1978) (emergency/exigent circumstances exception)