State v. Cortellesso

417 A.2d 299, 1980 R.I. LEXIS 1671
CourtSupreme Court of Rhode Island
DecidedJuly 8, 1980
Docket78-113-C.A.
StatusPublished
Cited by7 cases

This text of 417 A.2d 299 (State v. Cortellesso) 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
State v. Cortellesso, 417 A.2d 299, 1980 R.I. LEXIS 1671 (R.I. 1980).

Opinion

OPINION

DORIS, Justice.

This is an appeal by the defendants Albert Cortellesso (Cortellesso) and Martin A. DiRaimo (DiRaimo) from judgments of conviction in the Superior Court on charges of receiving stolen goods, a violation of G.L. 1956 (1969 Reenactment) § 11-41-2.

At approximately midnight on June 11, 1976, while on patrol, Detective Louis Nar-ciso (Narciso), of the North Kingstown police department observed a refrigerator trailer, without a tractor attached, parked next to a North Kingstown meat market, known as Rudy’s Market. Noting that the trailer had an out-of-state license plate and that its refrigerator unit was running, Nar-ciso decided to investigate. He located a metal box underneath the front of the trailer and unlatched and unhinged it, removing registration papers. After noting that portions of the trailer had been freshly painted, he compared the trailer’s license-plate number with the information contained in the registration papers and determined that they were different. Narciso notified police headquarters of this information and was in turn promptly informed that the trailer was listed as having been stolen a few days earlier from Massachusetts. Narciso then returned to police headquarters where he obtained a bolt cutter, which he used to cut a lock off the trailer doors. Upon opening the trailer doors, he discovered sides of beef inside the refrigerated unit. Narciso then called for assistance and staked out the trailer.

At approximately 7:45 a. m. on the same day, Narciso testified that he observed defendants drive by Rudy’s Market a few times in a large shiny black car and then stop at the meat market. Cortellesso then entered the meat market, exiting a few minutes later with the market’s owner. They proceeded to the trailer where they climbed into the back for a few minutes. Cortellesso then returned to his car and drove off.

At approximately 11 a. m. defendants returned to the meat market in a small old car. The defendants entered Rudy’s Market where Narciso had now positioned himself dressed as an employee. Narciso testified that Cortellessd said they would sell the meat to the meat market for $22,000 and that “we got it from some Irish kids in Boston and they don’t mess around, they want their money.” Following this conversation, defendants, the owner of the meat market and Narciso (still undercover) proceeded to the trailer. When Cortellesso picked up a side of beef, the police arrested both him and DiRaimo.

At trial Cortellesso testified that he and DiRaimo had gone to the meat market not to sell the meat but to buy it. He explained that he had not picked up the meat on his first trip to the store because he had not wanted to dirty his shiny new car with the bloody sides of beef. Cortellesso denied having made any statement regarding his obtaining the meat from “Irish kids.”

On October 4, 1976, defendants filed a motion to suppress the trailer, the registra *301 tion papers removed from the trailer’s metal box, and the sides of beef and a motion to dismiss the indictments on the ground that they were based on “unauthorized, illegal and unlawfully seized evidence.” The Superior Court denied both these motions. The jury found each defendant guilty of two counts of receiving stolen goods. The trial justice denied defendants’ motion for a new trial. They are now appealing their judgments of conviction to this court.

The defendants raise several issues on appeal. They claim that the warrantless search of the trailer violated their Fourth Amendment rights against unreasonable searches and seizures. They also argue that the prosecutor violated their Fifth Amendment right against self-incrimination by asking them why they had not told the police their version of the incidents before trial. The defendants further argue that the trial justice erred in denying their motion for judgment of acquittal and in allowing Cortellesso’s alleged admission into evidence before the state proved corpus delicti.

Before examining the first issue it is necessary to determine whether defendants have standing to challenge the warrantless search of the trailer and the seizure of its contents.

The defendants clearly have the burden of establishing their standing to challenge the admissibility of the seized evidence. State v. Jardine, 110 R.I. 491, 494, 293 A.2d 901, 903 (1972). Our review of the record indicates that defendants did not satisfy this burden.

Modern law on standing begins with Jones v. United States, 362 U.S. 257, 80 S.Ct. 725, 4 L.Ed.2d 697 (1960). Prior to Jones, standing to contest an unlawful search was narrowly restricted to those who had either a proprietary or possessory interest in the premises searched. The Jones Court effected a significant liberalization of the standing requirement. First, they establish the concept of automatic standing for a defendant charged with a possessory crime. In so doing, the Court eliminated the defendant’s dilemma of having to gain standing to challenge the admissibility of evidence by claiming a proprietary interest in the very contraband the possession of which is the crime charged, only to have such damaging admissions introduced at trial.

Second, Jones explicitly broadened the class of persons protected by taking the standing that was already available to persons who had a proprietary or possessory interest in the premises and extending it to all who are legitimately on the premises.

Since 1960 the Court has continued to evolve its concept of standing. Two cases, Simmons v. United States, 390 U.S. 377, 88 S.Ct. 967, 19 L.Ed.2d 1247 (1968) and Rakas v. Illinois, 439 U.S. 128, 99 S.Ct. 421, 58 L.Ed.2d 387 (1978), reh. denied 439 U.S. 1122, 99 S.Ct. 1035, 59 L.Ed.2d 83 (1979), have made some major modifications to the Jones concept of standing. In Simmons the Court held that whenever a defendant testifies at a suppression hearing to contest the legitimacy of a search or seizure, his testimony may not be used against him at trial. As noted by this court, this decision essentially has rendered the concept of automatic standing superfluous:

“The sole purpose for giving automatic standing to an accused possessor has been done away with by the Simmons’ decision. The first of the alternative grounds for giving standing in Jones has been eliminated. It is pure surplusage.” State v. Jardine, 110 R.I. at 495, 293 A.2d at 903 (footnote omitted). 1

In Rakas, the Court retreated from its holding in Jones that any person “legitimately on the premises” has standing to challenge the admissibility of evidence *302 seized thereon.

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Bluebook (online)
417 A.2d 299, 1980 R.I. LEXIS 1671, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-cortellesso-ri-1980.