State v. Ernest Sabourin

Citations

• 161 A.3d 1132
• 2017 WL 2507853
• 2017 R.I. LEXIS 82

Syllabus

The defendant, Ernest Sabourin, appealed from a judgment of conviction after a jury found him guilty on two counts of first-degree sexual assault. The defendant had been accused by a woman, both of whom believed was his daughter, of sexually assaulting her at a time when she was too intoxicated to resist. The trial justice sentenced the defendant to twenty-five years on the first count and twenty-five years on the second count, to run concurrently with the first count. On appeal, the defendant argued that his oral statements to the police should have been suppressed because he was in custody while in his home and was subject to interrogation by the police without the benefit of Miranda warnings. He further contended that his post-Miranda statements were inadmissible because the police employed the \question first\ interrogation technique, a practice found unconstitutional by the United States Supreme Court in Missouri v. Seibert, 542 U.S. 600 (2004). With respect to the statements the defendant made in his apartment, the Supreme Court held that the defendant was not interrogated by the detectives and that, therefore, his statements were voluntary. The Court reasoned that the detective's questions were merely instinctive reactions to the defendant's unprompted statements. As a result, the Supreme Court did not find it necessary to determine the custody analysis. Furthermore, the Court held that the Central Falls detectives did not engage in the \question first\ interrogation technique. The Court reasoned that, because it held that the interrogation requirement was missing, Miranda warnings were not required before they were given at the police station, when the defendant was in custody and interviewed by the lead detective. Lastly, the Supreme Court held that the defendant's waiver of his Miranda rights at the police station was voluntary, knowing, and intelligent. The Court agreed with the hearing justice's finding that there was no evidence of any interaction betwe