State v. Trearra Hudgen

Syllabus

The defendant, Tre'arra Hudgen, appealed from a Superior Court judgment of conviction for first-degree murder, discharge of a firearm when committing a crime of violence that caused death, conspiracy to assault with a firearm, felony assault with a firearm, first-degree robbery, and carrying a revolver without a license or permit. On appeal, the defendant alleged that the trial justice erred in (1) denying her motions to suppress the evidence found at her apartment, (2) denying her motion to suppress the evidence found in her vehicle, and (3) violating her right to confront a witness about promises, rewards, and inducements. The Supreme Court held that the defendant waived her claim that the search warrant for her apartment lacked particularity, because she did not raise it before the trial justice nor did it fall within the exception to the raise-or-waive rule there was a substantial basis in the affidavit to establish probable cause to issue the warrant and the trial justice did not err in denying her request for a Franks hearing. Because the Supreme Court concluded the warrant was valid, the Court did not consider defendant's argument that the trial justice erred in relying on the good-faith exception. The Supreme Court then determined that the warrantless vehicle seizure did not violate defendant's rights under the collective-knowledge doctrine, Connecticut law enforcement officers properly relied on information provided by the Pawtucket Police Department to establish probable cause that the defendant's vehicle contained evidence of a crime. Lastly, the Supreme Court determined that the defendant failed to preserve a Confrontation Clause issue for appeal because defendant did not raise the argument before the trial justice. Accordingly, the Supreme Court affirmed the judgment of conviction of the Superior Court.