William Lamont Thomas v. Omar Proctor et al.

63 A.3d 881 (R.I. 2013) · Supreme Court of Rhode Island · April 17, 2013 · No. 2011-309-Appeal (PC 05-6410)

Summary

The Rhode Island Supreme Court affirmed a Superior Court judgment entered after a jury found for a Providence police officer in a civil action arising from the officer’s shooting of William Lamont Thomas. The Court held that the trial justice did not abuse his discretion under Rhode Island Rule of Evidence 403 by admitting a redacted police database report containing Thomas’s mug shot and reference to a prior arrest for possession of a shotgun.

Holdings

  1. The trial justice did not abuse his discretion by admitting the redacted report because the report was relevant to what Proctor knew at the time of the shooting and its probative value was not substantially outweighed by the danger of unfair prejudice.
  2. Admission of the redacted report did not warrant a new trial, and the Superior Court properly denied Thomas's motion for a new trial.

Questions Presented

  1. Whether the trial justice abused his discretion under Rhode Island Rule of Evidence 403 by admitting a redacted police department database report containing Thomas's mug shot and a reference to a prior arrest for possession of a shotgun.
  2. Whether the admission of the redacted report unfairly prejudiced Thomas so as to require a new trial.

Disposition

affirmed

Cases Cited (8)

  • State v. Tetreault, 31 A.3d 777, 782 (R.I. 2011)(followed)
  • State v. Dellay, 687 A.2d 435, 439 (R.I. 1996)(followed)
  • State v. DeJesus, 947 A.2d 873, 883 (R.I. 2008)(followed)
  • Chapdelaine v. State, 32 A.3d 937, 941 n.1 (R.I. 2011)(followed)
  • State v. Dinagen, 639 A.2d 1353, 1356-58 (R.I. 1994)(followed)
  • State v. Lemon, 456 A.2d 261, 265 (R.I. 1983)(followed)
  • State v. Bowden, 439 A.2d 263, 269 (R.I. 1982)(followed)
  • State v. Robertson, 740 A.2d 330, 336 (R.I. 1999)(followed)

Cited In (0)

No citing cases on record yet.

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