## Facts

- On November 24, 1994 (Thanksgiving), Michael Lambert (nearly 18) and William Page (18) encountered Sylvester Gardiner, a homeless man living under an I-95 overpass area in Providence, leading to a confrontation.
- Page displayed a BB gun resembling a firearm, forced Gardiner to the ground, directed Lambert to find a rope, and Gardiner was hog-tied; Lambert acknowledged the gun belonged to him.
- Gardiner was severely beaten and later died; both Lambert and Page gave police statements admitting they struck Gardiner at least in part.
- Gardiner’s body was found on November 26, 1994; police apprehended Lambert and Page that night, and Lambert initially gave a false name before later providing his correct identity.
- After the incident, Lambert and Page spoke with a group of youths; Page said they had beaten an older man, and Lambert added details (including striking the man with a gun and a tube). A witness later testified about the conversation but could not always distinguish which speaker made particular remarks.
- Lambert moved pretrial to suppress his custodial statement, claiming his Miranda waiver was not knowing, intelligent, and voluntary; the trial court denied the motion.
- At trial, Lambert objected to admitting Page’s statements and any ambiguous “both of them” statements; the trial court admitted the conversation as adoptive admissions by Lambert, and the jury convicted Lambert of second-degree murder and committing a crime of violence while armed with a firearm.
- The trial court denied Lambert’s motion for a new trial.

## Issues

1. Whether Lambert’s custodial statement should have been suppressed because his Miranda waiver was not knowing, intelligent, and voluntary under the totality of the circumstances, including his age.
2. Whether testimony recounting Page’s inculpatory statements during the group conversation was inadmissible hearsay or properly admitted against Lambert as adoptive admissions.
3. Whether the trial court erred in denying Lambert’s motion for a new trial as against the weight of the evidence.

## Decision

- The Supreme Court of Rhode Island affirmed the convictions.
- The court held Lambert’s Miranda waiver was knowing, intelligent, and voluntary under the totality of the circumstances; the custodial statement was properly admitted.
- The court held Page’s inculpatory remarks during the group conversation were admissible against Lambert as adoptive admissions based on Lambert’s own comments and conduct.
- The court held the trial justice properly denied the motion for a new trial because the verdict was supported by the evidence and the trial justice did not overlook or misconceive material evidence.

## Legal Principles

- The validity of a Miranda waiver turns on whether it was voluntary, knowing, and intelligent under the totality of the circumstances; a defendant’s age is relevant but not dispositive.
- A statement made in a party’s presence may be treated as an adoptive admission when the circumstances would naturally call for denial if untrue and the party’s silence, conduct, or corroborating statements indicate acceptance of the statement.
- On review of a denial of a motion for a new trial, appellate courts defer to the trial justice’s independent assessment of credibility and weight of the evidence and will not disturb the ruling absent clear error, including overlooking or misconceiving material evidence.

## Conclusion

The court upheld Lambert’s convictions, concluding that his near-eighteen status and the interrogation circumstances supported a valid Miranda waiver, that Page’s account of the beating was admissible as Lambert’s adoptive admission given Lambert’s confirming details and lack of repudiation, and that the evidence supported the jury’s verdict.


State v. Lambert, 705 A.2d 957 (R.I. 1997)