State v. Bunnell

Summary

The Rhode Island Supreme Court affirmed Katherine Bunnell’s convictions for second-degree murder and conspiracy to commit murder arising from the fatal beating of her three-year-old nephew. The court held that the trial justice properly admitted only those portions of a coconspirator’s police interview that were sufficiently self-inculpatory under Rhode Island Rule of Evidence 804(b)(3), and it affirmed the denial of Bunnell’s motion for a new trial.

Holdings

1. A "statement" under Rhode Island Rule of Evidence 804(b)(3) refers to individual declarations within a longer narrative, not the entire confession or interview. Only declarations that are sufficiently against the declarant's penal interest are admissible under the exception.
2. Rule 106 was unavailable to Bunnell because she was the party introducing the recorded statement in the first instance.
3. The trial justice properly denied Bunnell's motion for a new trial because he conducted the required independent assessment of the evidence, credibility, and verdict, and did not overlook or misconceive material evidence.

Questions Presented

1. Whether the trial justice erred by admitting only portions of Delestre's police interview under Rhode Island Rule of Evidence 804(b)(3), rather than admitting the entire interview.
2. Whether the trial justice erred in denying Bunnell's motion for a new trial based on alleged inconsistencies in the babysitter's testimony.
3. Whether Rhode Island Rule of Evidence 106 required admission of additional portions of Delestre's recorded interview.

Disposition

affirmed