Summary
The Rhode Island Supreme Court affirmed Susan LaPlante’s convictions for fraudulently obtaining public assistance and giving a false document to a public official. The court held that the trial justice did not abuse his discretion by denying a mistrial after an investigator unexpectedly mentioned the defendant’s ownership of timeshares, because timely curative instructions and individual juror voir dire adequately addressed any potential prejudice.
Topics
Practice areas
Questions Presented
- Whether the trial justice abused his discretion by denying LaPlante's motion for a mistrial after a State witness unexpectedly mentioned the family's timeshare ownership.
- Whether the curative instruction and individual juror voir dire were sufficient to cure any prejudice from the witness's unsolicited testimony.
Holdings
- The trial justice did not abuse his discretion by denying LaPlante's motion to pass the case and declare a mistrial because the witness's fleeting, unelicited timeshare comment was not sufficiently inflammatory to render the jury unable to fairly decide the case.
Key quotations
“When ruling on a motion to pass a case, this Court will reverse a trial justice's ruling on appeal only if it was clearly wrong.” (70)
“If the trial justice determines that the prejudice is curable, he or she must issue a timely and effective instruction.” (71)
“Therefore, after viewing Martinez's comment in the context of the testimony in which it was given, and in light of the curative instruction and voir dire, we believe the trial justice was not clearly wrong when he determined that the jury was not affected by any prejudice arising from the timeshares.” (72)
Factual background
During LaPlante's trial for welfare fraud and filing a false document, a state investigator unexpectedly testified that her application contained information about family-owned timeshares, despite a pretrial ruling that the State was not to elicit that information. Defense counsel immediately moved for a mistrial, arguing that the testimony could cause jurors to view LaPlante as able to afford vacations and conclude that she was running a fraud scheme. The trial justice gave a curative instruction, individually questioned the jurors, and found that most had not heard the remark and that those who had could disregard it.
Procedural history
LaPlante was charged with welfare fraud, food-stamp fraud, and filing a false document with a public agency. After a jury trial, she was acquitted of food-stamp fraud but convicted of welfare fraud and filing a false document; the Superior Court imposed suspended sentences, probation, and restitution. The Rhode Island Supreme Court affirmed after concluding that the trial justice did not abuse his discretion in denying the motion to pass the case.