State v. Joseph Coletta

Syllabus

The defendant, Joseph Coletta (Mr. Coletta or defendant), appealed from a Superior Court judgment of conviction following a jury trial at which he was found guilty of five counts of second-degree child molestation. On appeal, the defendant argued that the trial justice erred in (1) denying his motion to suppress his post-arrest statement to police because it was obtained in violation of the Due Process Clauses of the Fourteenth Amendment to the United States Constitution and article 1, section 2 of the Rhode Island Constitution; (2) denying his motion to suppress his post-arrest statement to police because it was obtained in violation of Rule 5(a) of the District Court Rules of Criminal Procedure; (3) granting the state's motion in limine to preclude the defendant's false-confessions expert from testifying; and (4) denying the defendant's motion for a new trial. The defendant waived his argument that the trial justice erred in denying his motion to suppress under the Rhode Island Constitution. The Supreme Court evaluated whether the denial of the defendant's motion to suppress was clearly erroneous under the Fourteenth Amendment to the United States Constitution, and whether his statement to police was obtained in violation of Rule 5(a) of the District Court Rules of Criminal Procedure. Because the defendant gave his post-arrest police statement knowingly, intelligently, and voluntarily, and any purported delay in his presentment to the District Court under Rule 5(a) was not operative in inducing his statement, the Supreme Court concluded that the trial justice did not clearly err in denying the motion to suppress. Furthermore, the Supreme Court held that the trial justice did not abuse her discretion in granting the state's motion in limine to preclude the defendant's expert witness from testifying about false confessions because the defendant failed to alert the trial justice that scientific or medical evidence was at issue. Finally, the Supreme Court concluded th