Lynch v. State
13 A.3d 603
| R.I. | 2011Background
- Lynch was convicted of five counts of sexual assault against his sixteen-year-old developmentally disabled daughter.
- Lynch appealed to the Rhode Island Supreme Court and his conviction was affirmed in 2004.
- Lynch filed a postconviction relief application alleging ineffective assistance of counsel, prosecutorial misconduct, and insufficiency of the evidence.
- The postconviction relief judge denied the application after a May 1, 2007 hearing.
- The Supreme Court avoided reexamining insufficiency of the evidence due to res judicata and addressed only the remaining claims.
- The Court affirmed the Superior Court’s judgment and remanded the case for execution of the decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance of counsel at trial | Lynch asserts counsel erred by not cross-examining Dr. McCue | Counsel’s decision was within professional discretion and credible testimony remained intact | No relief; not prejudicial under Strickland |
| Prosecutorial misconduct and witness coaching | Mary’s testimony was coached or rehearsed with prosecutors | Preparation of witnesses is permissible and did not render trial unfair | No misconduct; credibility found; no denial of fair trial |
| Sufficiency of the evidence (anal penetration) re: first-degree sexual assault | Anal penetration evidence insufficient without corroboration from Dr. McCue’s exam | Victim’s testimony alone suffices to prove guilt beyond a reasonable doubt | Res judicata; issue previously decided on direct appeal; no postconviction relief on this basis |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. Supreme Court, 1984) (establishes two-part standard for ineffective assistance of counsel)
- Washington v. State, 989 A.2d 94 (R.I. 2010) (deference to trial court findings; de novo review of law and constitutional questions)
- Rodrigues v. State, 985 A.2d 311 (R.I. 2009) (great deference to hearing justice's findings of fact; standard of review in postconviction relief)
- Hazard v. State, 968 A.2d 886 (R.I. 2009) (review of constitutional rights questions on postconviction relief; de novo on questions of law or fact)
- State v. Mastracchio, 612 A.2d 698 (R.I. 1992) (prosecutorial misconduct standard requiring substantial prejudice for reversal)
- Miguel v. State, 774 A.2d 19 (R.I. 2001) ( Strickland standard applied in Rhode Island for ineffective assistance claims)
- Dufresne v. State, 436 A.2d 720 (R.I. 1981) (prior authority cited on standard of effective assistance)