DeCiantis v. State
2011 R.I. LEXIS 114
| R.I. | 2011Background
- Anthony DeCiantis was convicted of first-degree murder in 1984 and given a life sentence.
- William Ferle, a prosecution witness in DeCiantis's murder trial, had multiple pending and uncharged offenses disclosed during testimony and cross-examination.
- DeCiantis filed a third postconviction-relief petition in 1998 alleging withholding of exculpatory information and prosecutorial misconduct.
- A 2005–2006 hearing addressed whether Ferle’s uncharged crimes and expense/disposition information were properly disclosed, and whether prosecutorial misconduct occurred.
- A 2007 decision denied postconviction relief; on appeal, the Rhode Island Supreme Court affirmed, applying Brady and Rule 16 principles and evaluating materiality and deliberate nondisclosure.
- The court clarified that uncharged acts of a witness should be disclosed if they are material for impeachment, and that deliberate nondisclosure triggers a different standard.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Ferle's uncharged crimes were obliged to be disclosed. | DeCiantis contends nondisclosure violated Brady. | State argues there was no obligation to disclose uncharged admissions. | Disclosures of uncharged offenses were required; materiality evaluated de novo. |
| Whether the nondisclosure was deliberate. | DeCiantis asserts deliberate nondisclosure occurred. | State argues nondisclosure was not deliberate. | Hearing justice did not find deliberate nondisclosure; materiality applied. |
| Whether there was prosecutorial misconduct by Leach. | DeCiantis asserts misconduct based on withholding evidence. | State contends Leach's testimony was credible and no misconduct occurred. | No prosecutorial misconduct found; credibility resolved in favor of the State. |
| Whether withholding undisclosed evidence affected the trial's outcome (materiality). | Nondisclosed evidence could have altered the verdict. | Additional disclosures would not have changed the result. | No reasonable probability the result would differ; evidence not material. |
Key Cases Cited
- State v. Chalk, 816 A.2d 413 (R.I. 2002) (expands discovery duties beyond Rule 16 for impeachment evidence)
- State v. Briggs, 886 A.2d 735 (R.I. 2005) (deliberate nondisclosure grounds for new trial; materiality framework)
- State v. McManus, 941 A.2d 222 (R.I. 2008) (Brady materiality includes impeachment and exculpatory evidence)