Summary
The Rhode Island Supreme Court affirmed James Enos's conviction for domestic assault with a dangerous weapon. The court held that the evidence was legally sufficient for a jury to find a substantive dating relationship under Rhode Island's Domestic Violence Prevention Act and that an unsolicited reference to Enos's post-Miranda silence did not require a mistrial because of the trial court's curative instruction. Justices Goldberg and Robinson dissented in part regarding the sufficiency of the evidence of a substantive dating relationship.
Topics
Practice areas
Questions Presented
- Whether the evidence was legally sufficient for a reasonable juror to find that Enos and Mary had been in a substantive dating relationship under G.L. 1956 § 12-29-2.
- Whether the trial justice erred in denying a mistrial after a police officer testified that Enos declined to provide information after receiving Miranda warnings.
Holdings
- The evidence was legally sufficient for a reasonable juror to find that Enos and Mary had been in a substantive dating relationship. The statutory factors concerning the relationship's length, type, and frequency of interaction guide the court's determination but do not require specific evidence or findings concerning each factor, and the statute does not restrict consideration to only those factors.
- The trial justice did not err in denying the motion for a mistrial after a witness made an unsolicited reference to Enos's post-Miranda silence because the immediate and thorough curative instruction prevented the brief remark from causing prejudice sufficient to inflame the jury or impair its impartial consideration of the evidence.
Key quotations
“The statute directs the court to look to three factors (length, nature, and frequency) as indicative of the substance of the relationship as a whole.” (21 A.3d at 331)
“While this remark certainly implicates the defendant's right to remain silent, any prejudice that may have arisen swiftly was foreclosed by the trial justice's immediate and thorough instruction to the jury.” (21 A.3d at 334)
Factual background
Enos and Mary met through Match.com in January 2008, dated for approximately six months, and had an intimate relationship before Enos ended the relationship in August 2008. They met at a restaurant to exchange jewelry, but after an argument Enos grabbed Mary, struck her with drinking glasses, and kicked her until restaurant employees intervened. After police arrived, Enos made an exclamation about what he had done, was advised of his Miranda rights, and declined to provide information about the incident.
Procedural history
Enos was charged by information with assault with a dangerous weapon under G.L. 1956 § 11-5-2 and the Domestic Violence Prevention Act. A jury convicted him of domestic assault with a dangerous weapon, and the Superior Court imposed a twenty-year sentence, with eighteen months to serve and eighteen and one-half years probation, together with other conditions. The Supreme Court treated his premature appeal as timely in the interests of justice, considered the appeal under a show-cause procedure, and affirmed.