State v. Alicia Williams, 137 A.3d 682

On August 10, 2012, Alicia Williams and Rick Butler (who lived in the same house) had a physical altercation; Williams admitted to grabbing a box cutter and swinging it, and Butler sustained cuts to his forearm.
Police officers responded twice: initially after the fight and later when Butler discovered an additional cut and called police. Officer Stephen Carrig photographed the scene and later testified at trial about observations.
Williams claimed she acted in self-defense after Butler punched her and charged at her; defense presented testimony from family members supporting that Butler was the initial aggressor.
At trial Williams was convicted by a jury of assault with a dangerous weapon (box cutter); the court instructed the jury on self-defense and the duty to retreat, and the jury asked a question about retreat during deliberations.
Williams moved for a new trial arguing the verdict was against the weight of the evidence; the trial justice denied the motion, finding the jury reasonably credited portions of Butler’s testimony that supported conviction.
On appeal Williams argued (1) the trial justice improperly excluded Officer Carrig’s testimony that she was “scared of Butler,” and (2) the trial justice erred in denying her motion for a new trial; the Supreme Court affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Williams)	Held
Admissibility of officer testimony that defendant was "scared of Butler"	Exclusion proper because the statement on DV/SA form likely memorialized defendant’s own statement (hearsay) and officer lacked personal knowledge tying fear to Butler	Officer Carrig’s testimony should be allowed as lay observation of defendant’s demeanor showing fear of Butler (relevant to self-defense)	Trial justice did not abuse discretion; testimony excluded because officer could not establish personal knowledge that fear was directed at Butler and may have been based on hearsay or insufficient foundation
Denial of motion for new trial (verdict against weight of evidence)	Jury reasonably credited portions of testimony supporting conviction; trial justice properly acted as "thirteenth juror" and reviewed credibility	Verdict against weight of evidence; trial justice overlooked material facts and failed to adequately address self-defense	Trial justice did not clearly err; denial affirmed because he sufficiently reviewed evidence, weighed credibility, and concluded reasonable minds could differ

State v. Harnois, 638 A.2d 532 (R.I. 1994) (limits use of officer testimony to introduce a defendant’s out-of-court exculpatory statements under hearsay/catchall concerns)
State v. Covington, 69 A.3d 855 (R.I. 2013) (lay witness may not opine on another person’s inner thoughts or feelings)
State v. St. Michel, 37 A.3d 95 (R.I. 2012) (standard for reviewing trial-justice evidentiary rulings: abuse of discretion and prejudice required to reverse)
State v. Karngar, 29 A.3d 1232 (R.I. 2011) (trial justice’s role as the "legendary thirteenth juror" when deciding new-trial motions alleging verdict is against the weight of the evidence)
State v. Mendez, 116 A.3d 228 (R.I. 2015) (appellate review of trial justice denial of new-trial motion: reverse only for clear error or overlooking material evidence)