Summary
The Rhode Island Supreme Court affirmed John Benoit’s conviction for entering an apartment with the intent to commit larceny. The court held that the evidence permitted a reasonable jury to infer that Benoit possessed the requisite intent when he entered the apartment and that the trial justice properly denied his motions for judgment of acquittal, mistrial, and a cautionary instruction. Justice Robinson concurred in part and dissented regarding the sufficiency of the evidence of intent at the time of entry.
Topics
Practice areas
Questions Presented
- Whether the evidence was sufficient to permit a reasonable jury to find that Benoit intended to commit larceny when he entered the apartment.
- Whether the trial justice abused his discretion by denying a mistrial and a cautionary instruction after an officer testified that he responded to a dispatch for a possible burglary in progress.
Holdings
- The evidence, viewed in the light most favorable to the state, was sufficient to permit a reasonable jury to infer that Benoit intended to commit larceny when he entered the apartment; therefore, the trial justice properly denied the motion for judgment of acquittal.
- The trial justice did not abuse his discretion by admitting the officer's testimony that he responded to a possible burglary in progress and by denying a mistrial and cautionary instruction because the testimony was admitted to explain the officer's state of mind and response, not for the truth of whether a burglary had occurred.
Key quotations
“It is reasonably obvious that intent may only be determined in the ordinary course of events by the subsequent actions of the accused.” (809)
“It would not be unreasonable for a jury to draw the inference that defendant intended to commit larceny when he entered the apartment, and therefore, that there was sufficient evidence, if accepted by the factfinder, to convict him of entering the apartment with the intent to commit larceny.” (811)
“We see nothing in that answer that could in any way be construed as indicating that the defendant actually committed a burglary” (812)
Factual background
Benoit was a worker hired to install trim and caulk around replacement windows and sliding glass doors at an apartment complex. He entered Christopher Gervais's apartment to work on a living-room sliding glass door, but about an hour later entered Gervais's bedroom, went directly to a dresser, and rifled through Gervais's wallet. When confronted, Benoit said that times were tough, returned the money, and offered to buy Gervais beer. A responding officer testified that the dispatch call concerned a possible burglary in progress, prompting Benoit's motion for a mistrial and a cautionary instruction.
Procedural history
A Kent County Superior Court jury convicted Benoit of entering an apartment with intent to commit larceny. The trial justice denied Benoit's motions for judgment of acquittal, mistrial, and a cautionary instruction. The Rhode Island Supreme Court summarily decided the appeal after a show-cause proceeding and affirmed the judgment of conviction.
Remand instructions
The papers were remanded to the Superior Court following affirmance of the judgment of conviction.