State v. Keith Harrison
66 A.3d 432
| R.I. | 2013Background
- Keith Harrison was convicted by a Providence County jury of simple domestic assault for head-butting Cassandra Bey on May 6, 2009; jury acquitted him of felony domestic assault and another simple domestic assault count.
- Defendant was sentenced to one year with nine months to serve and three months suspended with probation.
- Harrison moved to suppress evidence related to handcuffs found in his studio apartment and argued Fourth and Fifth Amendment violations; the suppression hearing was held February 11, 2011.
- Patrolman DeCecco testified Bey reported head-butting and showed wrist injuries; police later entered Harrison’s apartment with consent and discovered handcuffs and knives on a dresser.
- At trial, the court permitted testimony about a knife in plain view; it suppressed the handcuffs but allowed testimony regarding the admission that Harrison owned handcuffs to be cross-examined.
- Harrison challenged the denial of his motion for a new trial, arguing Bey’s testimony was not credible and the verdict did not do substantial justice; the trial court denied the motion and the Supreme Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of handcuff admission | Admission stemmed from investigation, not illegally seized evidence. | Admission was elicited during custodial interrogation in violation of Miranda and/or from illegally obtained evidence. | Admission admissible; not in custody and Miranda does not apply. |
| Fourth Amendment challenge to admission | Handcuff admission did not result from illegal search and seizure. | Evidence derived from unlawful entry should be barred. | No Fourth Amendment violation; admission allowed after independent review. |
| New trial standard and credibility | Jury verdict supported by the weight of the evidence; trial court properly denied new trial. | Bey’s credibility failures warrant a new trial. | Trial court did not err in denying the motion for a new trial. |
Key Cases Cited
- Goulet, 21 A.3d 302 (R.I. 2011) (independent review on suppression; standard of review)
- Jimenez, 33 A.3d 724 (R.I. 2011) (definition of interrogation; not custody)
- Caruolo, 524 A.2d 575 (R.I. 1987) (custody analysis; Miranda applicability)
- Hobson, 648 A.2d 1369 (R.I. 1994) (police presence and coercion in interrogation)
- Wong Sun v. United States, 371 U.S. 471 (U.S. 1963) (fruit of the poisonous tree concept; unconstitutional entry)