State v. Sendra Beauregard, 198 A.3d 1

Victim Pamela Donahue was shot to death on December 2, 2014; Sendra Beauregard (defendant) was later charged with murder and related firearm offense.
Police interviewed Beauregard multiple times; she was Mirandized in the first and second interviews but requested counsel during the second; detectives continued questioning after she asked for an attorney. The state conceded the second–fourth interviews violated Miranda and suppressed those statements at trial.
During later interviews (third and fourth), defendant led police to a buried handgun and ammunition in Scituate; police recovered the gun and ammo the next morning. Those physical items were admitted at trial.
Police located and towed defendant’s car the night of December 3, 2014, then obtained a warrant and searched it on December 4, recovering a shell casing and cell phones.
At pretrial suppression hearings the trial justice concluded (1) Patane governs and therefore physical evidence derived from voluntary but unwarned statements is admissible; (2) defendant’s statements were voluntary; and (3) impoundment and search of the vehicle were supported by probable cause/the automobile exception. The Superior Court denied suppression; defendant was convicted and appealed.

Issue	State's Argument	Beauregard's Argument	Held
Whether physical evidence found after unwarned but voluntary statements must be suppressed	Patane controls: Miranda violation does not require exclusion of non‑testimonial physical fruits if statements were voluntary	Rhode Island Constitution should provide broader protection than Patane; exclude physical fruits	Court adopts Patane; physical evidence admissible if statements voluntary
Whether defendant’s statements (that led to gun) were voluntary	Police conduct was not coercive; totality of circumstances shows voluntariness	Mental illness, delays between interviews, misrepresentations, and continued questioning after requests for counsel rendered statements involuntary	Statements were voluntary under clear‑and‑convincing evidence standard; Patane applies
Whether impoundment/search of defendant’s vehicle violated Fourth Amendment	Probable cause existed (witness timeline, surveillance); automobile exception and later warrant validate seizure/search	Police lacked probable cause; impoundment tainted resulting evidence	Trial justice’s probable‑cause finding affirmed; automobile exception applies; seizure/search lawful
Whether state constitution affords greater self‑incrimination protections than federal law	Federal and RI precedent are coextensive; follow federal rule	Urged expansion of RI constitutional protections beyond Patane	Court declines to expand; RI article 1, §13 treated as coextensive with Fifth Amendment

United States v. Patane, 542 U.S. 630 (Sup. Ct.) (Miranda violation does not require suppression of nontestimonial physical evidence derived from voluntary unwarned statements)
Miranda v. Arizona, 384 U.S. 436 (Sup. Ct.) (Miranda warnings and right to counsel framework)
Wong Sun v. United States, 371 U.S. 471 (Sup. Ct.) (fruit‑of‑the‑poisonous‑tree doctrine for verbal evidence)
Maryland v. Shatzer, 559 U.S. 98 (Sup. Ct.) (14‑day safe harbor before police may reinitiate interrogation after invocation of counsel)
Colorado v. Connelly, 479 U.S. 157 (Sup. Ct.) (Fifth Amendment voluntariness focuses on governmental coercion)
New York v. Quarles, 467 U.S. 648 (Sup. Ct.) (limitations on extending Miranda prophylaxis)
State v. Werner, 615 A.2d 1010 (R.I.) (automobile exception applies when probable cause exists even if vehicle in police custody)
State v. Bertram, 591 A.2d 14 (R.I.) (Rhode Island self‑incrimination analysis coextensive with federal protections)