92 A.3d 920
R.I.2014Background
- Morris was indicted for two separate Pawtucket robberries in violation of G.L. 1956 § 11-39-1(a).
- Pawtucket detectives pursued leads across jurisdictions, identifying Morris via vehicle and clothing from surveillance.
- Detectives conducted a pat-down in Providence, seized a U-Haul receipt, and later arrested Morris outside Pawtucket’s jurisdiction.
- A Superior Court hearing suppressed several items as fruits of an unlawful extra-jurisdictional arrest, including the U-Haul receipt and related testimony.
- The Rhode Island Supreme Court granted review to decide whether Fourth Amendment principles require suppression for an extraterritorial arrest under state law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Fourth Amendment exclude evidence from an extra-jurisdictional arrest? | Morris argues exclusion is required due to unlawful extraterritorial arrest. | State contends Moore allows non-exclusion where arrest is constitutionally permissible. | No exclusion required; Fourth Amendment not implicated. |
| Are state-law jurisdictional limits and exceptions controlling here? | State asserts hot pursuit or emergency exceptions apply; otherwise arrest was unauthorized. | Morris contends detectives exceeded authority, triggering suppression. | Neither hot pursuit nor emergency exception applies; arrest unauthorized but not suppressible under Fourth Amendment. |
| What is the appropriate remedy for an unauthorized extraterritorial arrest? | Suppression should follow from violation of state jurisdictional limits. | Exclusionary rule should deter improper state-law conduct; however, not required here under federal standards. | Exclusion not mandated; evidence admitted. |
Key Cases Cited
- Virginia v. Moore, 553 U.S. 164 (2008) (arrest permissible under federal constitution may not require suppression for state-law violation)
- Wong Sun v. United States, 371 U.S. 471 (1963) (exclusionary rule as to tainted evidence; deterrent, not personal right)
- Calandra, 414 U.S. 338 (1974) (exclusionary rule's remedy is deterrent, not automatic if rights were not violated)
- Ryan, 731 F.3d 66 (1st Cir. 2013) (extraterritorial arrest outside federal jurisdiction; not automatically suppressive)
- Hagan, 819 A.2d 1256 (R.I. 2003) (extraterritorial transport of a prisoner in lawful custody for duties; jurisdictional restraints weighed)
- Berker, 120 R.I. 849 (1978) (state arrest authority governed by statute; probable cause sufficiency noted)
- Musterd, 56 A.3d 931 (R.I. 2012) (deference to trial court; de novo review for legal questions)
- Jackson, 570 A.2d 1115 (R.I. 1990) (exclusionary rule balancing restrained by societal interests)
- Taveras, 39 A.3d 638 (R.I. 2012) (Fourth Amendment reasonableness; balancing totality of circumstances)