State v. Alfred Bishop
68 A.3d 409
R.I.2013Background
- Home-invasion and murder in Warwick on June 27, 2007; Ceasar and Claire Medeiros survived while Gabriel Medeiros died; intruder identified as Alfred Bishop by witnesses and later matched by DNA; police used a composite sketch and photo array; Bishop was on parole at the time and later arrested; trial admitted Ceasar’s alcohol evidence but limited drug-use evidence per Handy procedure.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of intoxication evidence under Handy | State argues Handy procedure not met; drugs shown not probative of intoxication. | Bishop contends evidence of witnesses’ intoxication should be admitted to impeach credibility. | Trial court did not abuse discretion; Handy not satisfied; exclusion affirmed. |
| Admission of Bishop’s parole status under Rule 403 | Parole evidence highly relevant to opportunity, knowledge, identity, intent. | Parole evidence overly prejudicial and should be excluded. | Court did not abuse discretion; parole evidence admitted for limited permissible purposes with curative instructions. |
| Cross-examination scope regarding drug use | Evidence of drug use by witnesses should be fully explored. | Expert testimony not required; evidence must meet Handy standard. | Trial court appropriately limited cross-examination; no reversible error. |
Key Cases Cited
- Handy v. Geary, 105 R.I. 419 (R.I. 1969) (intoxication admissibility under Handy gatekeeping procedure)
- Avarista v. Aloisio, 672 A.2d 887 (R.I. 1996) (impeachment use of intoxication evidence limited by Handy)
- Rice v. State, 755 A.2d 137 (R.I. 2000) (Handy standard applied to intoxication and drugs in impeachment)
- Clark v. State, 974 A.2d 558 (R.I. 2009) (abuse-of-discretion standard for evidentiary rulings; Handys framework applied)
- Ahmadjian v. State, 438 A.2d 1070 (R.I. 1981) (application of Handy to drugs and intoxication)
- Mattatall v. State, 114 R.I. 568 (R.I. 1975) (Handy framework extended to narcotics evidence)
- DeJesus v. State, 947 A.2d 873 (R.I. 2008) (Rule 403 discretion narrowly construed; prejudice balancing)
- Woodson v. State, 551 A.2d 1187 (R.I. 1988) (parole evidence relevance balanced against prejudice)