State v. Adam Lake
2014 R.I. LEXIS 66
| R.I. | 2014Background
- Avis, age 11, disclosed to sister Marion in 2009 that Lake, her stepfather, had sexually molested her multiple times.
- Indictment charged Lake with three counts of first‑degree child molestation sexual assault covering 2008–2009.
- Trial in January 2012; verdicts: guilty on Counts 1 and 3, acquitted on Count 2; defense argued evidence lacked distinction among counts.
- Medical experts testified that Avis showed minimal hymenal tissue, suggesting multiple instances of vaginal penetration and abuse.
- Trial court denied a motion for a new trial; Lake was sentenced to two concurrent 40‑year terms with 25 years to serve.
- The Rhode Island Supreme Court affirmed, holding the trial judge properly applied the ‘thirteenth juror’ standard and credible evidence supported Counts 1 and 3.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of motion for a new trial was proper | Lake argues the court overlooked material evidence and misweighed credibility. | Lake contends verdicts not supported by substantial justice. | Trial court's denial affirmed; credible testimony supported Counts 1 and 3. |
| Credibility assessment of the complaining witness | Avis’s credibility undermines the verdict due to inconsistencies. | Variations in testimony show unreliability that should negate verdicts. | Trial judge appropriately weighed credibility; credibility supported verdicts. |
| Sufficiency of medical corroboration for counts 1 and 3 | Medical findings corroborate vaginal penetration and abuse. | Medical testimony is weak corroboration and not dispositive. | Medical testimony properly corroborated the able testimony for Counts 1 and 3. |
| Impact of acquittal on Count 2 on other verdicts | Acquittal on Count 2 should not undermine Counts 1 and 3. | Different weight of evidence across counts undermines consistency. | Acquittal on Count 2 does not undermine Counts 1 and 3 given differing evidence. |
Key Cases Cited
- State v. Rosario, 35 A.3d 938 (R.I. 2012) (thirteenth juror standard for new-trial motions)
- State v. Guerra, 12 A.3d 759 (R.I. 2011) (three-step credibility and weight framework)
- State v. Paola, 59 A.3d 99 (R.I. 2013) (careful review of trial court credibility determinations)
- State v. Harrison, 66 A.3d 432 (R.I. 2013) (defers to trial court credibility assessments in new-trial review)
- State v. DiCarlo, 987 A.2d 867 (R.I. 2010) (record should reflect some rationale for new-trial ruling)
- State v. Jensen, 40 A.3d 771 (R.I. 2012) (consistency and credibility may be weighed against minor inconsistencies)
- State v. Gonzalez, 56 A.3d 96 (R.I. 2012) (mere disagreement with credibility is not enough for new trial)
- State v. Clay, 79 A.3d 832 (R.I. 2013) (weight of evidence standard in new-trial review)