Summary
The Rhode Island Supreme Court affirmed Matthew Jones's convictions for two counts of felony assault. The court held that the second trial justice did not abuse his discretion under Rhode Island Rule of Evidence 609 by admitting Jones's 1996 felony assault conviction for impeachment, and that the law of the case doctrine did not preclude reconsideration based on the expanded record.
Topics
Practice areas
Questions Presented
- Whether the law of the case doctrine barred the second trial justice from reconsidering the admissibility of Jones's 1996 felony assault conviction after the first trial ended in a mistrial.
- Whether the trial justice abused his discretion under Rule 609 of the Rhode Island Rules of Evidence by admitting the 1996 felony assault conviction to impeach Jones's credibility.
Holdings
- The law of the case doctrine did not control the second trial justice's evidentiary ruling because the second trial presented an expanded record and occurred in the context of a new trial after a mistrial.
- The trial justice acted within his broad discretion in admitting Jones's 1996 felony assault conviction to impeach his credibility because its probative value was not substantially outweighed by its prejudicial effect.
Key quotations
“The law of the case doctrine provides that, ‘after a judge has decided an interlocutory matter in a pending suit, a second judge, confronted at a later stage of the suit with the same question in the identical manner, should refrain from disturbing the first ruling.’” (at 7)
“This is especially true as it relates to evidentiary rulings at trial.” (at 8)
“Rule 609 of the Rhode Island Rules of Evidence permits the admission of a witness’s prior conviction to attack that witness’s credibility unless the court determines that the prejudicial effect of the conviction substantially outweighs its probative value.” (at 9)
“Accordingly, under these circumstances, the trial justice did not abuse his discretion by allowing the state to impeach the defendant’s credibility with the 1996 felony assault conviction.” (at 10)
Factual background
On March 4, 2013, an altercation occurred at Jones's apartment building involving neighbors Josef Tallo and Fatima P. DaSilva. The State's evidence showed that Jones struck Tallo and DaSilva in the head with a golf club, while Jones testified that he was attacked and swung the club in self-defense, unintentionally striking the victims. Jones testified at trial and acknowledged that he had multiple prior convictions, including a 1996 felony assault conviction. The trial justice allowed the State to refer to that conviction as felony assault for the limited purpose of assessing Jones's credibility.
Procedural history
Jones was charged in Providence County Superior Court with two counts of felony assault arising from a March 4, 2013 altercation. His first jury trial ended in a mistrial after a hung jury. At the second trial, a different trial justice admitted certain prior convictions, including the 1996 felony assault conviction, for impeachment under Rule 609. The jury convicted Jones on both counts, and the Rhode Island Supreme Court affirmed.