Miguel Tebalan Rivera v. State of Rhode Island

CourtSupreme Court of Rhode Island
DecidedJune 25, 2024
Docket2021-0076-M.P.
StatusPublished

This text of Miguel Tebalan Rivera v. State of Rhode Island (Miguel Tebalan Rivera v. State of Rhode Island) is published on Counsel Stack Legal Research, covering Supreme Court of Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Miguel Tebalan Rivera v. State of Rhode Island, (R.I. 2024).

Opinion

Supreme Court

No. 2021-76-M.P. (PM 20-8909)

Miguel Tebalan Rivera :

v. :

State of Rhode Island. :

NOTICE: This opinion is subject to formal revision before publication in the Rhode Island Reporter. Readers are requested to notify the Opinion Analyst, Supreme Court of Rhode Island, 250 Benefit Street, Providence, Rhode Island 02903, at Telephone (401) 222-3258 or Email opinionanalyst@courts.ri.gov, of any typographical or other formal errors in order that corrections may be made before the opinion is published. Supreme Court

Present: Suttell, C.J., Goldberg, Robinson, Lynch Prata, and Long, JJ.

OPINION

Chief Justice Suttell, for the Court. We issued a writ of certiorari to review

a Superior Court judgment granting Miguel Tebalan Rivera’s application for

postconviction relief. The state challenges the trial justice’s finding of ineffective

assistance of counsel, contending that the trial justice (1) overlooked or

misconceived evidence that trial counsel advised Rivera that he would need to testify

in order to assert that he killed the decedent in self-defense; (2) erred in finding that

trial counsel otherwise performed deficiently in “discourag[ing]” Rivera from

testifying and in failing to move to exclude Rivera’s recorded statement to police;

and (3) erred in relying on Rivera’s statements at sentencing and in a presentence

report to find that trial counsel’s performance prejudiced Rivera.

For the reasons set forth herein, we affirm the judgment of the Superior Court.

-1- I

Facts and Travel

The Offense

On the night of December 23, 2015, Rivera entered a Providence Police

Department substation, repeatedly insisting that he had killed someone. According

to officers who were present, Rivera was “yelling,” “very emotional,” “crying,” and

“stuttering.” He spoke to officers in Spanish. Officer Eduardo Curi, a Spanish-

speaking patrolman, testified that Rivera said “that they made him do it[] [b]ecause

* * * they were not giving him a job” and “that they did something to his family in

Guatemala.” Rivera offered to take Officer Curi to the scene of the killing. Officer

Curi placed Rivera in the back seat of his cruiser, uncuffed, and proceeded to Moore

Street. Officer Richard Mendez, also a Providence police patrolman, followed

behind.1

When the officers and Rivera arrived at his apartment building, he gave the

officers his keys and directed them to the correct unit. Inside, police discovered the

body of Julio Mejia Perez, who lay dead on the kitchen floor. Perez appeared to

have been stabbed repeatedly. Detective David Perez, who had responded to the

Moore Street location, seized a bloody knife from the top of the refrigerator.

1 At the time of the trial, Officer Mendez testified that he was currently a detective.

-2- The Recorded Statement

Rivera was arrested and taken into custody. He later made a statement to

police. Detective Daniel O’Connell interviewed Rivera with the aid of a Spanish-

speaking officer, who acted as an informal interpreter after Rivera indicated that he

was not proficient in English.2

The two officers initially provided Rivera with a Spanish-language waiver

form, describing his rights under Miranda v. Arizona, 384 U.S. 436 (1966), which

Rivera signed. After confirming certain biographical details, Rivera repeatedly and

explicitly told the officers that he did not want to talk to them. The Spanish-speaking

officer responded that the “truth is * * * what will help you” and continued to

question Rivera. In response to the detective’s questions, Rivera explained that

Perez was someone he knew from Guatemala, his country of origin, who had helped

him get a job.

After the Spanish-speaking officer asked how he was paid, Rivera again stated

that he did not want to talk to the officers and asked to speak to a lawyer. Detective

O’Connell responded by inquiring whether Rivera had a lawyer, to which Rivera

replied that he did not, but that he believed, based on the warnings he had been given,

2 The trial justice’s decision granting postconviction relief identifies the Spanish-speaking officer who participated in the custodial interview as Officer Curi. We were unable to corroborate Officer Curi’s involvement in the interview from the record before us.

-3- that he could be provided with one. The Spanish-speaking officer persisted in

questioning him, asking how the fight started and whether Perez and Rivera were

drinking. Rivera said he did not want to say something that would be used against

him. Detective O’Connell replied that the police “have to give you your rights” and

that “no matter if you are not a citizen or not, everyone gets their constitutional

rights.” The Spanish-speaking officer explained that those rights were “automatic.”

The two then continued to interrogate Rivera.

In the disjointed interview that followed, Rivera eventually expressed that he

and Perez had been in the apartment for approximately three hours before the fight

began. He claimed that Perez sought to collect money that Rivera did not have and

that Perez stated that Rivera had “screwed up” and had no way out. He characterized

Perez as someone who was always intimidating others.

Rivera admitted to having stabbed Perez at least twice with a knife that was

on top of the refrigerator. He also indicated that Perez did not have a weapon. Rivera

commented that he felt guilty, to which the Spanish-speaking officer responded that

it was fine, because he was defending himself. The interrogation ended at 10:13

p.m., having lasted approximately 44 minutes.

The Statement of Admissions

In April 2016, a grand jury returned a two-count indictment against Rivera

alleging murder, in violation of G.L. 1956 §§ 11-23-1 and 11-23-2, and the

-4- commission of a crime of violence while in possession of a knife with a blade more

than three inches long, in violation of G.L. 1956 § 11-47-59.

On May 9, 2017, Rivera’s initial counsel was replaced by the attorney whose

representation is the subject of Rivera’s postconviction-relief application (trial

counsel). Trial counsel later testified that Rivera’s first attorney withdrew after

Rivera rejected a plea of nolo contendere to second-degree murder. Trial counsel

averred that, when she began representing Rivera, her understanding was that he did

not want to enter that plea because he wished to assert self-defense at trial.

The month that she began representing Rivera, trial counsel drafted a

document titled “Statement of Admissions.” Rivera signed the statement, which was

styled as an affidavit, before a notary on May 26, 2017. It declared Rivera’s

intention to waive his right to a jury trial and to admit that, on “December 23, 2015,

at 121 Moore Street 3[rd] floor in the City and County of Providence, [he] did stab

Julio Mejia Perez who was born on May 9, 1979, multiple times, with a kitchen knife

which was later recovered from that location, which was the proximate and actual

cause of his death.” It concluded: “I do not waive my right to trial by a judge sitting

without a jury on the issue of mens rea – that is, whether I had criminal intent.”

At a June 2017 hearing, which was conducted by a different justice than the

one who would eventually oversee his trial, Rivera affirmed his desire to waive his

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Kimmelman v. Morrison
477 U.S. 365 (Supreme Court, 1986)
Williams v. Taylor
529 U.S. 362 (Supreme Court, 2000)
Gonzalez v. United States
128 S. Ct. 1765 (Supreme Court, 2008)
Michael Bell v. State of Rhode Island
71 A.3d 458 (Supreme Court of Rhode Island, 2013)
Joseph Hall v. State of Rhode Island
60 A.3d 928 (Supreme Court of Rhode Island, 2013)
Joseph Jolly v. A.T. Wall
59 A.3d 133 (Supreme Court of Rhode Island, 2013)
Firlando Rivera v. State of Rhode Island
58 A.3d 171 (Supreme Court of Rhode Island, 2013)
Small Business Loan Fund Corp. v. Gallant
795 A.2d 531 (Supreme Court of Rhode Island, 2002)
State v. Rancourt
435 A.2d 1095 (Supreme Judicial Court of Maine, 1981)
Ogden Ex Rel. Rath-Roth v. Rath
755 A.2d 795 (Supreme Court of Rhode Island, 2000)
Lerner v. Ursillo
765 A.2d 1212 (Supreme Court of Rhode Island, 2001)
State v. McKone
673 A.2d 1068 (Supreme Court of Rhode Island, 1996)
State v. Pacheco
763 A.2d 971 (Supreme Court of Rhode Island, 2001)
State v. Rieger
763 A.2d 997 (Supreme Court of Rhode Island, 2001)
State v. Diefenderfer
970 A.2d 12 (Supreme Court of Rhode Island, 2009)
State v. Briggs
886 A.2d 735 (Supreme Court of Rhode Island, 2005)
Rice v. State
38 A.3d 9 (Supreme Court of Rhode Island, 2012)
State v. Forand
958 A.2d 134 (Supreme Court of Rhode Island, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
Miguel Tebalan Rivera v. State of Rhode Island, Counsel Stack Legal Research, https://law.counselstack.com/opinion/miguel-tebalan-rivera-v-state-of-rhode-island-ri-2024.