State v. Joseph Corcoran

Syllabus

The State of Rhode Island appealed from a Superior Court order granting a motion to suppress statements made to the police by the defendant. The state argued that the trial justice erred in finding that the defendant was in custody at the time he made incriminating statements at the scene of an automobile accident and that the rights read to the defendant at the time of his arrest for driving under the influence and at the police station were sufficient to apprise him of his constitutional rights.<br><br>The Supreme Court concluded that the trial justice correctly determined that the defendant was in custody once the defendant was relocated and the officer, armed with all of the indicia of the defendant's intoxication, informed the defendant of his belief that the defendant was being untruthful about consuming alcohol—followed by further interrogation to that effect. Additionally, the Supreme Court concluded that the issue of the sufficiency of the Miranda warnings was not properly before the Court because the trial justice did not address this issue and the state did not assign error to the trial justice's reason for suppressing the defendant's post-arrest statements as fruits of the poisonous tree. Accordingly, the Supreme Court affirmed the order of the Superior Court.<br>