State v. Daniel Tejeda

Citations

• 171 A.3d 983

Syllabus

The defendant, Daniel Tejeda, was convicted of first-degree murder in a jury trial. On appeal, the defendant argued that his trial commenced outside the statutory time period required by the Interstate Agreement on Detainers Act, G.L. 1956 § 13-13-2. Additionally, he contended that the trial justice erred in denying his motions to suppress the seizure of his cell phone and its records, as well as the bags, zip ties, and a BB gun found in his apartment. The defendant also asserted that the trial justice erred in permitting the admission of some of the defendant's statements taken while he was in the hospital. Finally, the defendant maintains that his sentence pursuant to the habitual offender statute was unduly harsh. The Supreme Court concluded that there was no violation of the Interstate Agreement on Detainers Act as the defendant's federal sentence had expired well in advance of trial, nullifying any rights he had under the act. However, even if the act still applied to the defendant at the time of trial, the brief delay in beginning the trial was due to the defendant's own pretrial motions, which the Court held, in any event, was not sufficient to warrant dismissal of the case pursuant to the act. Next, the Court upheld the denial of the defendant's motion to suppress the seizure of his cell phone during his arrest because, deferring to the trial justice's findings of fact, the Court concluded that he did not clearly err in finding one of the arresting officers to be a credible witness as compared to the defendant. Even given some inconsistencies among the law enforcement officers' testimony, the trial justice's decision to find the defendant's testimony hard to believe was not clear error. Further, the Court concluded that the trial justice did not err in permitting evidence discovered pursuant to two warrants because the affidavits supporting those warrants demonstrated probable cause. The defendant pointed to a number of purported falsehoods in both affidavit