State v. Joseph Corcoran

CourtSupreme Court of Rhode Island
DecidedMay 26, 2022
Docket20-121
StatusPublished

This text of State v. Joseph Corcoran (State v. Joseph Corcoran) 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. Joseph Corcoran, (R.I. 2022).

Opinion

May 26, 2022

Supreme Court

No. 2020-121-C.A. (W3/18-464A)

State :

v. :

Joseph Corcoran. :

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

Justice Goldberg, for the Court. This case came before the Supreme

Court on April 5, 2022, on appeal by the State of Rhode Island, seeking review of a

Superior Court order granting a motion to suppress all statements made to police

by the defendant, Joseph Corcoran. The state argues that the trial justice erred in

finding that the defendant was in custody at the scene of an automobile collision

and, therefore, erroneously suppressed the statements that the defendant made to

the officers at the time. Additionally, the state avers that the rights the police

officer read to the defendant at the time of his arrest and at the police station were

sufficient to apprise the defendant of his constitutional rights—an issue the trial

justice did not reach. For the reasons set forth in this opinion, we affirm the order

of the Superior Court.

-1- Facts and Travel

During the evening of October 23, 2018, Westerly police officer Travis

Nichols arrived at the scene of an accident on Route 78 eastbound in Westerly,

Rhode Island, where he learned from a witness that defendant’s vehicle had struck

a light pole on the side of the ramp approaching Route 78. According to the

witness, after observing the collision, he checked on defendant and noticed that he

smelled of alcohol; the witness shared this information with Officer Nichols and

also identified defendant, who was standing outside of the driver’s-side door of his

vehicle, as the driver of the vehicle that struck the light pole. After speaking with

the witness, Officer Nichols approached defendant and observed damage to the

passenger-side front bumper, hood, and roof of defendant’s vehicle, and that the

vehicle’s airbags had deployed. The light pole was on the ground. Although

defendant did not appear injured and told the officer that he was uninjured, the fact

that the airbags deployed prompted Officer Nichols to request an ambulance.1

While speaking with defendant, Officer Nichols noted the tell-tale signs of

intoxication. The defendant’s eyes were bloodshot and watery; his speech was

slurred; and his breath smelled of alcohol. At that point, Officer Nichols asked

defendant “if he had consumed any alcoholic beverages[,]” to which defendant

1 Officer Nichols testified that it is a typical—and, we suggest, rather prudent— practice to have someone medically screened when airbags have deployed in a collision, regardless of whether the person appears injured or not.

-2- replied, “[N]o.” Officer Nichols then requested that defendant move to the front of

his vehicle, away from the driver’s-side door. Before conducting three field

sobriety tests, Officer Nichols testified, he informed defendant that he had

“suspicions that [defendant] had been drinking, even though he first said that he

hadn’t,” and he proceeded to “ask[] [defendant] again if he had been drinking.”

The defendant then admitted that he had been drinking and that he had consumed

“two beers.” A “backup” police officer, Officer Toscano, arrived at the scene; and,

while Officer Nichols conducted field sobriety tests, which indicated that

defendant was impaired, an ambulance arrived and parked approximately ten feet

in front of defendant’s vehicle on Route 78.

The emergency medical technicians approached defendant, who remained

near Officer Nichols. At that point, Officer Toscano approached Officer Nichols

to report that, after the collision, the witness saw defendant toss something into the

woods bordering the side of the road. Officer Nichols then asked defendant if he

had thrown anything into the woods, to which defendant responded in the negative.

Officer Toscano inspected the area and retrieved a paper bag containing three

empty forty-two-ounce bottles of high-alcohol-content beer.2 When Officer

2 State’s Exhibit 2 presented at the hearing on the motion to suppress in the Superior Court was a photograph of the empty beer bottles from the paper bag that was thrown into the woods. Although state’s Exhibit 5, the Influence Report Form from the date of the arrest, states that he consumed two “40 oz” beers, the

-3- Nichols again asked defendant if he had thrown the bag into the woods, defendant

responded, “[Y]es.” At that point, Officer Nichols testified, “while Patrolman

Toscano stood by with the suspect,” he retrieved a preliminary breath test from his

patrol vehicle and asked defendant to take the test. (Emphasis added.) The

defendant agreed to submit to the test, which registered at a level of 0.201. He was

placed under arrest “for suspicion of DUI.”

After he arrested defendant and placed him in the police cruiser, Officer

Nichols read defendant a “Rights For Use At Scene” card, which provided:

“You are suspected of driving while under the influence of intoxicating liquor and/or drugs.

“You have the right to remain silent. You do not have to answer any questions or give statements. If you do answers questions or give statements, they can and will be used in evidence against you in court. You have the right to an attorney. If you cannot afford an attorney, one will be provided for you. “You have the right to be examined at your own expense immediately by a physician selected by you. You will be afforded a reasonable opportunity to exercise this right.”3

photograph displays three bottles of “Steel Reserve,” each indicating “42 ounce” on the label. 3 Officer Nichols did not read the reverse side of the “Rights For Use At Scene” card to defendant, which is titled “Constitutional Rights” and provides, in full, that:

-4- Upon arriving at the Westerly police station, Officer Nichols read defendant the

“Rights For Use At Station/Hospital” form, which provided, in pertinent part, that:

“You are under arrest for operating a motor vehicle while under the influence of intoxicating liquor * * *.

“You have the right to remain silent. You do not have to answer any questions or give statements. If you do answer questions or give statements, they can and will be used in evidence against you in court. You have the right to an attorney. If you cannot afford an attorney, one will be provided for you.”

After defendant was allowed a confidential phone call, Officer Nichols filled

out an “Influence Report Form” while asking defendant a series of questions and

recording his answers. The defendant admitted that he had been operating a

“1) You have the right to remain silent. You do not have to give a statement or answer any questions.

“2) If you give up your right to remain silent, anything you say can and will be used against you in a Court of Law.

“3) You have the right to the presence of a lawyer and to talk with a lawyer before and during any questioning. “4) If you cannot afford a lawyer and you want one, a lawyer will be appointed for you at no cost to you before any questioning.

“5) If you do talk to the police, you can stop at any time.

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State v. Joseph Corcoran, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-joseph-corcoran-ri-2022.