State v. Medeiros

Summary

The Supreme Court of Rhode Island affirmed Joseph Medeiros's convictions for sexual assault and child molestation. The court held that evidence of a prior sexual misconduct incident was properly admitted under Rhode Island Rule of Evidence 404(b), and that the trial justice did not overlook or misconceive material evidence when finding Medeiros guilty and denying his motion for a new trial.

Holdings

1. The prior witness statement was admissible because the prior misconduct was similar to the charged conduct, not remote, and relevant to show a common scheme or plan to sexually assault young girls in Medeiros's family; its probative value was not substantially outweighed by the danger of unfair prejudice.
2. The trial justice did not err in adjudicating Medeiros guilty or in denying his motion for a new trial because she did not overlook or misconceive material evidence and was not clearly wrong in crediting the complaining witness's testimony.

Questions Presented

1. Whether the Superior Court abused its discretion by admitting a prior victim's 1990 witness statement under Rhode Island Rule of Evidence 404(b).
2. Whether the Superior Court improperly adjudicated Medeiros guilty by overlooking or misconceiving material evidence and whether it erred in denying his motion for a new trial under Rule 33.

Disposition

affirmed