State v. Chalk

Summary

The Rhode Island Supreme Court affirmed Michael B. Chalk’s convictions for four sexual-assault offenses involving three minors. The court held that the late disclosure of Harmony Hill records and a juvenile record did not violate due process or warrant a mistrial or continuance, that evidence of an uncharged sexual act was properly admitted under Rhode Island Rule of Evidence 404(b), and that the trial justice properly denied the motion for a new trial.

Holdings

1. The late disclosure did not violate due process or Brady because the record did not show deliberate suppression and the defendant failed to establish a reasonable probability that earlier disclosure would have produced a different verdict.
2. The trial justice did not abuse his discretion by denying the defendant's motions for a mistrial or continuance.
3. The trial justice properly admitted testimony concerning an earlier sexual touching of the same complainant because it was sufficiently proximate and similar and was admitted for the limited purpose of showing Chalk's lewd disposition toward that complainant.
4. The trial justice properly denied the motion for a new trial because he independently assessed the credibility and weight of the evidence, articulated a sufficient rationale, and was not clearly wrong.

Questions Presented

1. Whether the late production of Harmony Hill records and information concerning the complainant's juvenile record violated due process or required a mistrial or continuance.
2. Whether the trial justice abused his discretion by admitting evidence of an uncharged sexual assault under Rule 404(b) to show Chalk's lewd disposition toward the same complainant.
3. Whether the trial justice erred in denying Chalk's motion for a new trial based on the asserted insufficiency and credibility problems in the evidence.

Disposition

affirmed