State v. Tracey Barros

Summary

The Rhode Island Supreme Court affirmed Tracey Barros’s conviction, holding that his confession was voluntary and that the trial judge properly denied his motion to suppress it, and that the trial judge correctly excluded the defendant’s proposed third‑party‑perpetrator evidence because the offer of proof was not reasonably specific. The Court relied on de novo review of voluntariness after deferring to the trial judge’s factual findings, and on the established requirement that a third‑party defense must show motive, opportunity, and a proximate connection. Justice Flaherty dissented in part, arguing for a cautionary jury instruction on unrecorded interrogations, while Chief Justice Suttell concurred with the majority and endorsed Flaherty’s comments on electronic recording.