Rice v. State
2012 R.I. LEXIS 22
| R.I. | 2012Background
- Rice appeals postconviction relief denial; alleges trial-counsel ineffective for strategic decisions, including medical-evidence strategy and witness usage.
- Trial counsel investigated medical testimony but chose not to call a physician expert; Rice was consulted and agreed with the decision.
- Counsel used a nurse practitioner and a DCYF worker to impeach the victim, which opened the door to cross-examination and potential corroboration.
- Evidence showed counsel’s decisions were tactical and based on trial strategy, not deficient performance.
- Rice also asserted newly discovered evidence from a 2003 medical article; the hearing denied this ground as not meeting criteria.
- Superior Court denied all claims; Rice timely appealed the postconviction relief denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did trial counsel's decision not to call the medical expert amount to ineffective assistance? | Rice | State | No; decisions were tactical and reasonable under Strickland. |
| Did trial counsel's use of nurse practitioner and DCYF worker as witnesses constitute ineffective assistance? | Rice | State | No; tactical decisions that did not rise to deficient performance. |
| Was the newly discovered evidence claim properly rejected? | Rice | State | Yes; evidence not sufficiently credible or undiscoverable pre-trial. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance of counsel: deficiency and prejudice)
- Ouimette v. State, 785 A.2d 1132 (R.I. 2001) (strong presumption of reasonable professional assistance)
- Brennan v. Vose, 764 A.2d 168 (R.I. 2001) (reasonableness of counsel's strategic decisions)
- Rodriguez v. State, 941 A.2d 158 (R.I. 2008) (objective standard of reasonableness for performance)
- Toole v. State, 748 A.2d 806 (R.I. 2000) (tactical decisions do not constitute ineffective assistance)
- State v. D'Alo, 477 A.2d 89 (R.I. 1984) (reasonable competency standard for representation)
- Page v. State, 995 A.2d 934 (R.I. 2010) (deference to trial-justice credibility findings in postconviction review)
- Brown v. State, 964 A.2d 516 (R.I. 2009) (burden of proof and standard of review in postconviction relief)