State v. Richard Baribault

Syllabus

The defendant, Richard Baribault, appealed from a judgment of conviction following a trial by a jury for second-degree murder, receiving stolen goods, conspiracy, operating a vehicle on a suspended license, and carrying a knife greater than three inches in length. On appeal, the defendant offered an array of arguments which, he contended, should have caused his conviction to be vacated. First, he argued that the trial justice erred by failing to suppress the fruits of his third interrogation by the Warwick Police Department, because the delay between his arrest and presentment to a judicial officer exceeded that permissible under Rule 5(a) of the Superior Court Rules of Criminal Procedure and the Fourth Amendment to the United States Constitution. Next, he asserted that the trial justice abused his discretion by failing to redact certain recorded prejudicial statements that the defendant made while he was in the interrogation room, but outside the presence of his interrogators. Those video recordings were later shown to the jury. Third, he contended that his detention by the Warwick Police Department was extensive, and that he was denied prescription medication during his detention in violation of his Fifth Amendment rights. Lastly, the defendant maintained that the trial justice abused his discretion by failing to suppress a witness's out-of-court identification. After thoroughly reviewing the record, the Supreme Court first held that any delay between defendant's arrest and presentment to a judicial officer was not violative of Rule 5(a) or the Fourth Amendment because there was no causative effect between the delay and any inculpatory statements that defendant made during the delay. Next, the Court held that the trial justice did not abuse his discretion by declining to redact certain statements that defendant made in the interrogation room because the probative value of those statements were not outweighed by their prejudicial effect. The Court did not address t