Lynch v. State
86 A.3d 390
R.I.2014Background
- Raymond Lynch was convicted in 1998 of three counts of first-degree sexual assault and two counts of second-degree sexual assault and sentenced to concurrent terms totaling sixty years; convictions affirmed on direct appeal in 2004.
- Lynch filed a first application for postconviction relief (PCR); the Superior Court denied it and this Court affirmed in 2011.
- Lynch filed a second PCR application (Nov. 15, 2011) raising multiple claims: improper admission of evidence under R.I. R. Evid. 803(4), ineffective assistance of counsel, violation of right to an impartial jury, excessive sentence, failure to disclose friendly interactions of the complaining witness to the jury, prosecutorial misconduct, and jury consideration of perjured testimony.
- Lynch’s appointed PCR counsel moved to withdraw under Shatney; the Superior Court granted withdrawal and Lynch proceeded pro se.
- The Superior Court dismissed the second PCR as barred by res judicata under G.L. 1956 § 10-9.1-8, finding no basis to invoke the narrow ‘‘interest of justice’’ exception; this appeal followed.
Issues
| Issue | Lynch's Argument | State's Argument | Held |
|---|---|---|---|
| Admission of evidence under Rule 803(4) | Trial court erred admitting certain evidence in violation of Rule 803(4) | Issue was or could have been raised previously and is barred | Dismissed as barred by res judicata; not allowed under interest-of-justice exception |
| Ineffective assistance of counsel | Trial counsel was constitutionally ineffective | Claim could have been raised earlier and is procedurally barred | Dismissed as barred by res judicata |
| Right to impartial jury / failure to reveal friendly interactions | Jury was deprived of facts about witness’s friendly interactions outside presence of jury | Matter could have been raised before; procedurally barred | Dismissed as barred by res judicata |
| Sentence disproportionality / Rule 35 relief | Sentence was disproportionately high compared to similar cases | Sentencing challenge should have been raised via Rule 35(a); not proper in this PCR | Not considered on merits; procedural remedy is Rule 35(a); PCR rejected |
| Prosecutorial misconduct / perjured testimony | Prosecutor misconduct and jury reliance on perjured testimony denied fair trial | Issues could have been raised earlier and are barred by res judicata | Dismissed as barred by res judicata |
Key Cases Cited
- State v. Lynch, 854 A.2d 1022 (R.I. 2004) (direct-appeal decision affirming convictions)
- Lynch v. State, 13 A.3d 603 (R.I. 2011) (affirming denial of first postconviction application)
- Shatney v. State, 755 A.2d 130 (R.I. 2000) (procedure for appointed counsel to move to withdraw in PCR context)
- Perez v. State, 57 A.3d 677 (R.I. 2013) (scope of postconviction relief statutory remedy)
- State v. Thornton, 68 A.3d 533 (R.I. 2013) (§ 10-9.1-8 codifies res judicata in PCR context)
- Ferrell v. Wall, 971 A.2d 615 (R.I. 2009) (res judicata bars issues that could have been litigated previously)
- Mattatall v. State, 947 A.2d 896 (R.I. 2008) (recognizes narrow interest-of-justice exception to res judicata in PCR cases)