State v. Jeremiah

696 A.2d 1220, 1997 R.I. LEXIS 213, 1997 WL 351250
CourtSupreme Court of Rhode Island
DecidedJune 25, 1997
Docket96-20-C.A.
StatusPublished
Cited by7 cases

This text of 696 A.2d 1220 (State v. Jeremiah) 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. Jeremiah, 696 A.2d 1220, 1997 R.I. LEXIS 213, 1997 WL 351250 (R.I. 1997).

Opinion

OPINION

FLANDERS, Justice.

A search warrant that fails to “describ[e] as nearly as may be * * * the place to be searched” violates article 1, section 6, of the Rhode Island Constitution. Any evidence seized pursuant to such a warrant must be suppressed and may not be used to convict a person, whose constitutional rights *1221 have been violated by the use of this type of overbroad or general writ. See, e.g., State v. Costakos, 101 R.I. 692, 694-96, 226 A.2d 695, 696-97 (1967). Because the search warrant employed here did not describe the place to be searched “as nearly as may be,” we conclude that it violated the constitutional right of the defendants, Andrew and Bruce Jeremiah (the Jeremiahs), to be free from unreasonable searches and seizures. Thus, the evidence garnered under its aegis should have been suppressed instead of being used to convict them. For this reason, we reverse the Superior Court’s judgments convicting the brothers Jeremiah of various drug-trafficking offenses.

Background

The Jeremiahs’ convictions stemmed from their alleged involvement in a- marijuana-distribution ring supposedly headquartered in the Silver Spring Center (Silver Center), a sprawling commercial park consisting of some eighteen multistory buildings 1 splayed across twelve acres of urbanscape, and all of it embraced within the misleadingly concise address designated on the warrant as 387-389 Charles Street, Providence, Rhode Island.

In early 1992 Patrick McNulty (McNulty), a state narcotics agent, began an investigation in Providence of a suspected marijuana-trafficking venture. A confidential informant (Cl) had told him that Andrew Jeremiah, John Steacy (Steacy), and a Mexican national (later identified as Jose Antonio Solis Ayerdi (Ayerdi)) were harboring approximately 600 pounds of cannabis that had been packed into two crates and stashed inside a warehouse at 387 Charles Street. 2 Informed that Steacy and Ayerdi were living high on the hog at a posh downtown Providence hotel, McNulty decided to intensify his surveillance of their activities. At some point he saw the two drive off in a car bearing dealer plates registered to Jeremiah Motors. The men led McNulty to Silver Center. Another member of the surveillance squad watched the same car pull into a garage in “Building 5” of that complex.

McNulty and other law enforcement officials, including Providence Police Detective Nicholas Cardarelli (Cardarelli), met to stra-tegize. Cardarelli prepared an affidavit (which relied almost exclusively on clues furnished by the Cl), and the police submitted a complaint to the District Court that sought authorization to search and seize contraband found in a “four story red brick factory complex with a loading dock and a large garage overhead door” located at “387 Charles Street.” (Emphases added.) On the basis of these submissions, a District Court master later issued a search warrant commanding authorized officers to seize any marijuana and drug paraphernalia found at the “387- 389 Charles Street Jeremiah Silver Ctr. Complex.” 3 (Emphasis added.)

McNulty set out to execute the warrant but temporarily refrained from doing so. Rather, posing as a fire inspector and accompanying the fire marshall, McNulty was allowed by Bruce Jeremiah to tour both building No. 4 (a four-story structure located at 389 Charles Street that has an overhead door and a loading dock) and building No. 5 (a three-story structure also located at 389 Charles Street that has an overhead door but no loading dock). During their inspection, something caught McNulty’s eye in building No. 5: two large crates stood next to the fire extinguisher, oil drums, and other warehouse bric-a-brac. Shortly after the tour ended McNulty flashed the warrant and pried open the crates. Inside, he discovered about 426 pounds of marijuana. Members of the search party then repaired to building No. 4, where they found several bags of marijuana near the Jeremiahs’ offices.

In due course a grand jury indicted the brothers Jeremiah, together with Steacy and Ayerdi, on a myriad of marijuana-related *1222 offenses. The Jeremiahs moved to suppress the evidence that had been seized during the search by challenging the particularity of the warrant used to obtain the incriminating evidence and by claiming that it violated the specificity requirement contained in both the State and the Federal Constitutions. 4

Following a hearing, a Superior Court justice denied their motions. The Jeremiahs proceeded to trial, and a jury convicted them of possessing marijuana with the intent to distribute and conspiring to achieve those ends. 5 These appeals ensued.

Analysis

Although the Jeremiahs challenge their convictions on multiple grounds, their core complaint is that the trial justice stumbled over the application of bedrock constitutional search and seizure principles when he denied their suppression motions. Specifically, they insist that the warrant used to search their premises gave the police too free a hand to rummage at will through a vast commercial area because it did not describe the place or places to be searched with the requisite particularity. See R.I. Const, art. 1, sec. 6; see also U.S. Const. Amend. IV. In assaying the Superior Court’s decision to deny the motions to suppress, we apply the clearly erroneous standard of review, mindful that we must examine the evidence in the light most hospitable to the state. State v. Roddy, 401 A.2d 23, 30 (R.I.1979). Having performed this task, we are left with the definite and firm conviction that the police crossed the constitutional line in obtaining the warrant and stepped out of legal bounds in executing it because it was much too general in its description of the area to be searched.

Article 1, section 6, of our constitution provides that “no warrant shall issue, but * * * upon probable cause, supported by oath or affirmation, and describing as nearly as may be, the place to be searched and the persons or things to be seized.” (Emphasis added.) 6 Like its federal analogue, see U.S. Const. Amend. IV, this provision reflects Rhode Island’s revulsion towards those general warrants known as writs of assistance that agents of the British Crown used to harass our colonial forebears. 7 Compare *1223 generally Telford Taylor, Two Studies in Constitutional Interpretation 19 (1969) (noting that “the fourth amendment was the product of particular events that closely preceded the Constitution and the Bill of Rights”) with Kevin D. Leitao, Rhode Island’s Forgotten Bill of Rights,

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Bluebook (online)
696 A.2d 1220, 1997 R.I. LEXIS 213, 1997 WL 351250, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-jeremiah-ri-1997.