Hector Jaiman v. State of Rhode Island
2012 R.I. LEXIS 137
R.I.2012Background
- Jaiman was convicted of first-degree murder, assault with intent to murder, and assault with a dangerous weapon, and the record on appeal concerns the postconviction relief denial.
- Muriel, the State’s key witness, had a plea deal to second-degree murder in exchange for testimony, and later memory lapses affected his trial testimony.
- Muriel testified at the first trial; at the second trial he refused to testify, claiming his plea required truthful testimony only once.
- During trial, Muriel’s police statement was read to the jury to refresh his recollection, and portions were admitted as a prior inconsistent statement.
- Jaiman raised multiple postconviction grounds, including ineffective assistance of counsel and improper prosecution vouching; the Superior Court denied relief, and this Court reviews that denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether postconviction relief on due-process grounds is barred by res judicata. | Jaiman (State) argues due-process claim was not raised on direct appeal. | State contends issue is barred by res judicata under DeCiantis. | Yes; barred by res judicata. |
| Whether an aider-and-abettor may be convicted of a more serious offense than the principal under § 11-1-3. | Jaiman contends illegal sentence; aider/abetter cannot receive greater punishment. | State argues statute allows same or greater liability; lenity not applicable. | Plain language allows aiding/abetting to be punished as principal; conviction proper. |
| Whether trial counsel was ineffective for failing to object to first-degree murder instruction. | Jaiman alleges Strickland deficiency and prejudice. | State asserts meritless or non-prejudicial objection failure. | No ineffective assistance; no prejudice established. |
| Whether trial counsel's failure to object to prosecutorial vouching for Muriel’s credibility was ineffective assistance. | Jaiman claims improper vouching affected trial fairness. | State argues comment was rebuttal; not objecting was strategic; judge instructed jurors. | No reversible error; one remark not prejudicial under Strickland and trial court instructions. |
Key Cases Cited
- State v. DeCiantis, 813 A.2d 986 (R.I. 2003) (res judicata applies to postconviction relief; relitigating issues barred)
- Tassone v. State, 42 A.3d 1277 (R.I. 2012) (criteria for postconviction review; waivers and procedural bars)
- State v. Graff, 17 A.3d 1005 (R.I. 2011) (statutory interpretation; plain language controls)
- Standefer v. United States, 447 U.S. 10 (U.S. 1980) (accomplice liability; conviction possible despite principal's acquittal)
- State v. Diaz, 654 A.2d 1195 (R.I. 1995) (accomplice liability; principal vs. aider/abettor distinction)
- State v. Davis, 877 A.2d 642 (R.I. 2005) (aiding and abetting not an element; symmetry not required)
- State v. Diefenderfer, 970 A.2d 12 (R.I. 2009) (cooperation agreements; vouching context)
- Lawn v. United States, 355 U.S. 339 (U.S. 1957) (reference to plea agreements not per se improper)
- Dockray, 943 F.2d 152 (1st Cir. 1991) (prosecutor may reference plea agreement; not automatic vouching)