State v. Richard Baribault, 247 A.3d 1237

Background

Victim Fernando “Captain Freddy” Silva was found dead aboard his sailboat; Baribault was later connected by witnesses, cell-phone/location data, and a knife with the victim's blood.
Baribault was arrested on Aug. 19, 2015, on misdemeanor charges; police conducted three recorded custodial interrogations before arraignment.
During the interrogations Baribault gave varying accounts; his third, at 12:25 p.m. the day after arrest, contained more inculpatory detail though he did not confess to murder.
Police relied on co-defendant Troy Gunderway’s statements, Google location history, surveillance, and recorded searches from Baribault’s phone at trial.
Baribault was convicted of second-degree murder, conspiracy, receiving stolen goods, suspended-license driving, and carrying a knife; sentenced to life plus a consecutive 10-year term.
On appeal Baribault challenged suppression of interrogation evidence (Rule 5(a)/Fourth Amendment), refusal to redact recorded out‑of‑presence statements (Rule 403), denial of medication during detention (Fifth Amendment), and suppression of an out‑of‑court ID.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Baribault)	Held
Whether statements from the third custodial interrogation must be suppressed for delay in presentment under Super. Ct. R. Crim. P. 5(a) / Fourth Amendment	Delay did not causally induce statements; defendant willingly spoke and waived rights; statements admissible	Delay between arrest and presentment was unnecessary and induced inculpatory statements, requiring suppression	Affirmed: even assuming Rule 5(a) noncompliance, defendant failed to show delay causally induced the statements; voluntariness established
Whether the trial justice abused discretion by refusing to redact a recorded statement Baribault made alone in the interrogation room (Rule 403)	Recording was relevant to defendant’s consciousness of guilt and credibility; probative value outweighed prejudice	Statement was highly prejudicial and likely to be construed as admission; should be excluded	Affirmed: trial justice did not abuse discretion—statement probative of awareness and not unfairly prejudicial
Whether denial of prescription medication during detention violated Fifth Amendment rights	(Not raised at trial)	Baribault contended lengthy detention and denial of meds impaired voluntariness of statements	Not addressed on appeal—issue waived for failure to raise at trial
Whether an out‑of‑court identification should have been suppressed	(Not raised at trial)	Baribault argued identification was unreliable and should be suppressed	Not addressed on appeal—issue waived for failure to raise at trial

Key Cases Cited

State v. Barros, 24 A.3d 1158 (R.I. 2011) (two-step Rule 5(a) analysis; defer to trial‑court factual findings, review voluntariness de novo)
State v. King, 996 A.2d 613 (R.I. 2010) (delay must causally induce statement; willing cooperation undermines causation)
State v. Nardolillo, 698 A.2d 195 (R.I. 1997) (elapsed time examined for causal effect on confession)
State v. Lionberg, 533 A.2d 1172 (R.I. 1987) (delay alone does not require suppression absent operative inducement)
Corley v. United States, 556 U.S. 303 (U.S. 2009) (federal presentment rule jurisprudence discussed but not controlling)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (custodial‑warning requirements)
State v. Patel, 949 A.2d 401 (R.I. 2008) (Rule 403 standard; appellate deference to trial court’s balancing)
State v. Doyle, 235 A.3d 482 (R.I. 2020) (harmless‑error framework for evidentiary rulings)