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68 A.3d 61
R.I.
2013
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Background

  • 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)
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Case Details

Case Name: State v. Roger Morin
Court Name: Supreme Court of Rhode Island
Date Published: Jun 18, 2013
Citations: 68 A.3d 61; 2013 WL 3013617; 2013 R.I. LEXIS 105; 2010-237-C.A.
Docket Number: 2010-237-C.A.
Court Abbreviation: R.I.
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    State v. Roger Morin, 68 A.3d 61