68 A.3d 61
R.I.2013Background
- Morin was indicted on sixteen counts of child molestation; counts 1-3 involved Sally and were severed from the remaining counts.
- A suppression hearing addressed Morin’s September 28, 1992 statement to Warren police after his arrest.
- Police obtained a custodial statement after Miranda rights were read; the state sought to admit the statement at trial.
- A trial court denied suppression and Morin moved to redact parts of the statement; the court declined redaction.
- Morin was convicted on count 1 (first-degree child molestation) and acquitted on count 2 (second-degree); count 3 had been dismissed.
- Morin argued on appeal that the suppression ruling, redaction decision, and denial of a new trial should be reversed; the Supreme Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Morin lawfully arrested with exigent circumstances warranting a warrantless arrest? | Morin argues arrest violated Payton and requires suppression. | State contends exigent circumstances justified arrest. | Arrest valid under exigent circumstances; suppression denied. |
| Should portions of Morin’s statement be redacted under Rule 403? | Redact counseling references and crude language to avoid prejudice. | Redactions unnecessary; statements probative. | No abuse of discretion; statement admitted in full. |
| Did the trial court abuse its discretion by denying Morin’s motion for a new trial? | Verdict logically inconsistent; new trial warranted. | No clear error; verdict supported by evidence. | No reversible error; new trial denial affirmed. |
Key Cases Cited
- Payton v. New York, 445 U.S. 573 (U.S. 1980) (warrantless home arrest exceptions; exclusionary rule discussed)
- New York v. Harris, 495 U.S. 14 (U.S. 1990) (exclusionary rule not applied to statements after warrantless arrest in home)
- State v. Goulet, 21 A.3d 302 (R.I. 2011) (exigent circumstances and probable cause analysis in arrests)
- Portes, 840 A.2d 1131 (R.I. 2004) (police urgency and emergency exception considerations)
- Brigham City, Utah v. Stuart, 547 U.S. 398 (U.S. 2006) (objective justification for warrantless police action in crises)
- In re Brown, 903 A.2d 147 (R.I. 2006) ( Rhode Island Fourth Amendment posture on exclusionary rule decisions)
- State v. Werner, 615 A.2d 1010 (R.I. 1992) (state constitutional approach to suppressive analysis)
- State v. Navarro, 33 A.3d 147 (R.I. 2011) (thirteenth juror standard for new trial motions)
- Pineda, 13 A.3d 623 (R.I. 2011) (guidance on weighing credibility and evidence in new trial rulings)
