Chapdelaine v. State, 32 A.3d 937

Chapdelaine was convicted on three counts of second-degree child molestation after a 2004 jury trial and sentenced to substantial periods with suspensions and probation.
He filed a postconviction relief petition in 2008 alleging ineffective assistance of trial counsel, Mark Smith, on four grounds.
Grounds included alleged conflict of interest, a stipulation limiting evidence about drugs/alcohol, lack of an expert to address psychological factors, and inadequate communication about plea negotiations.
The Superior Court denied relief in 2009; the Rhode Island Supreme Court subsequently remanded for final judgment and affirmed denial.
The court applied Strickland’s two-prong test (deficient performance and resulting prejudice) to evaluate trial-counsel claims.
The court concluded that counsel’s conduct was not deficient and that, even if some actions were imperfect, there was no reasonable probability the outcome would differ.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Plea negotiations and counsel's guidance	Chapdelaine asserts counsel failed to provide advice on a four-to-six year offer.	Smith testified he discussed the offer but Chapdelaine insisted on trial; lack of guidance did not render performance deficient.	No deficient performance; no prejudice established.
Conflict of interest	Counsel's prior representation of a witness’ mother created an actual conflict affecting cross-examination.	Waived consent and there was no divided loyalty; strategy was sound.	No actual conflict; waiver valid; performance not deficient.
Stipulation excluding drug/alcohol evidence	Stipulation unnecessarily foreclosed impeachment and favored the state.	Strategic choice to avoid opening doors to damaging cross-examination; reasonable under circumstances.	Reasonable strategic decision; not deficient under Strickland.
Failure to use an expert	Expert testimony could have explained psychological factors and alternative explanations for the victim's allegations.	Jury could assess credibility without an expert; no demonstrated prejudice; lack of necessity for an expert.	Not deficient; no prejudice evidenced; reasonable decision not to obtain an expert.

Moran v. Burbine, 475 U.S. 412 (U.S. 1986) ( Sixth Amendment attaches after charges; reasonable-competence standard for counsel)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance; objective standard of reasonableness; prejudice)
Rodriguez v. State, 941 A.2d 158 (R.I. 2008) (Strickland standard in Rhode Island postconviction relief)
Vose, 764 A.2d 168 (R.I. 2001) (Strickland framework and deference to counsel decisions)
Castore, 435 A.2d 321 (R.I. 1981) (credibility determinations reside with the jury; expert testimony not always required)
Rice, 755 A.2d 137 (R.I. 2000) (impeachment evidence of alcohol/drug use; not admissible to prove intoxication without issue)
Amirault, 677 N.E.2d 658 (Mass. 1997) (limits on expert psychiatric testimony to challenge credibility in certain child-abuse cases)
Boria v. Keane, 83 F.3d 48 (2d Cir. 1996) (conflict-of-interest and plea-negotiation context; not directly applicable, but discussed)