State v. Gauthier

Summary

The Rhode Island Supreme Court reviews a Superior Court finding that John E. Gauthier violated the conditions of his probation by assaulting another person. Applying the reasonably satisfactory evidence standard and a limited arbitrary-or-capricious review, the court holds that the hearing justice adequately assessed the witness testimony and affirms the judgment.

Holdings

1. The hearing justice did not act arbitrarily or capriciously in finding that reasonably satisfactory evidence established that Gauthier struck Simms and thereby violated the requirement that he keep the peace and remain of good behavior.
2. A probation violation may be sustained when the hearing justice finds the complaining witness only partially credible but relies on corroborating testimony from another credible witness and is reasonably satisfied that the violation occurred.

Questions Presented

1. Whether the Superior Court acted arbitrarily or capriciously in finding, based on reasonably satisfactory evidence, that Gauthier violated the conditions of his probation.
2. Whether the Superior Court could find a probation violation despite discrepancies in the complaining witness's account and its assessment that the witness was not wholly reliable.

Disposition

affirmed