State v. Sendra Beauregard

Syllabus

The defendant, Sendra Beauregard, appealed her conviction on one count of second-degree murder and one count of discharging a firearm while committing a crime of violence. On appeal, defendant argued that the trial justice erred in relying on United States v. Patane, 542 U.S. 630 (2004), in admitting the physical evidence police obtained as a result of statements the defendant gave to police during interviews that were in violation of Miranda. Moreover, defendant averred that her statements to police were involuntary and the product of coercion. Finally, defendant contended that the police lacked probable cause to seize her vehicle and therefore the trial justice erred in admitting the evidence seized from it. The Supreme Court adopted the United States Supreme Court's holding in Patane and determined that the physical evidence obtained through unwarned but voluntary statements is admissible. The Court also determined that the trial justice properly found that defendant's statements were voluntary and therefore the physical evidence that her statements led police to was admissible. Lastly, the Court concluded that police possessed sufficient probable cause to seize defendant's vehicle and that the evidence seized from the vehicle was similarly admissible. Therefore, the Court affirmed the judgment of conviction.