Eric Neufville v. StateState v. Eric Neufville, 172 A.3d 161

Background

Defendant Eric Neufville was presented as a probation violator after the State alleged he committed a December 27, 2013 apartment robbery while on probation. Victims were robbed at gunpoint by two men impersonating police officers.
Victim Bonnie Aguilar identified Neufville as the African‑American gunman at a probation‑violation hearing; other witnesses (Petrucci, Greer, and Detective Riley) provided corroborating testimony. The hearing justice found Aguilar credible and concluded Neufville violated probation.
The hearing justice revoked the suspension on Neufville’s longest sentence and executed a 16‑year prison term.
After the hearing, defense counsel discovered a previously undisclosed December 28, 2013 police statement by Aguilar that included descriptive details (e.g., hat on the white assailant, hoodie descriptions) that the defense argued were inconsistent with her trial identification.
Neufville filed a motion for reconsideration more than sixteen months after the judgment seeking relief based on the newly produced statement; the hearing justice reviewed the statement, reaffirmed Aguilar’s credibility, and denied the motion.
Neufville appealed only the sentencing decision (execution of the 16 years) and denial of the motion to reconsider; the Supreme Court affirmed, finding no arbitrary or capricious credibility finding and no abuse of discretion in sentencing or denial of relief.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the hearing justice acted arbitrarily or capriciously in crediting Aguilar’s identification	State: Aguilar’s trial testimony and corroborating witnesses supported the violation finding	Neufville: Aguilar’s prior police statement and prior misidentification undermined her credibility	Court: Hearing justice’s credibility determinations were supported by the record; not arbitrary or capricious
Whether the motion for reconsideration (based on newly produced police statement) warranted relief	State: Motion was untimely and, on merits, the new statement was not materially undermining	Neufville: New statement created inconsistency warranting reconsideration or another hearing	Court: Motion was filed too late under Rule 60(b) standards and, on the merits, the new statement was not sufficiently material to change the outcome
Whether execution of the full 16‑year suspended sentence was an abuse of discretion	State: Sentencing justice may consider the new offense plus prior criminal record when deciding execution	Neufville: Sentencing justice abused discretion by focusing on overall record/new offense rather than original probation offenses	Court: Considering defendant’s prior felony convictions and the new robbery offense, executing the full sentence was within the trial justice’s wide discretion
Whether appellate review was impeded by lack of sentencing transcript	State: N/A	Neufville: Appellant bears burden to supply transcript for meaningful review	Court: Noted defendant’s responsibility to provide transcripts; absence limits review but the record supported affirmance

Key Cases Cited

State v. Beaudoin, 137 A.3d 726 (R.I. 2016) (standard for probation‑violation hearings and deference to credibility findings)
State v. Prout, 116 A.3d 196 (R.I. 2015) (probation‑violation burden and credibility assessment principles)
State v. Raso, 80 A.3d 33 (R.I. 2013) (lower burden of proof in probation hearings than criminal trials)
State v. McKinnon‑Conneally, 101 A.3d 875 (R.I. 2014) (trial justice’s broad discretion to execute suspended sentences and focus on original offense)
State v. Fairweather, 138 A.3d 822 (R.I. 2016) (appellate review of probation‑violation sentences is for abuse of discretion)
Turdo v. Main, 132 A.3d 670 (R.I. 2016) (Rule 60(b) relief is discretionary and reviewed for abuse of discretion)
Shorrock v. Scott, 944 A.2d 861 (R.I. 2008) (appellant’s duty to supply transcript for meaningful appellate review)