State v. Antonio Acosta, 247 A.3d 489

Background

Antonio Acosta was indicted on one count of first-degree sexual assault and three counts of second-degree child molestation based on alleged incidents involving a family acquaintance, "Ivy," occurring between 2008 and 2012.
Ivy (a victim who later identified as male but was referred to by birth-name and female pronouns at trial) testified to multiple unwanted sexual contacts at ages 11–14; Acosta denied the allegations.
The prosecution’s case turned on Ivy’s testimony; defense highlighted inconsistencies in her statements and argued she had motive to lie after Acosta allegedly disclosed her gender/sexuality to family.
A Providence jury convicted Acosta on all four counts; he moved for a new trial arguing the verdict was against the weight of the evidence.
The trial justice conducted the required multi-step review, found Ivy’s testimony sufficiently credible and that reasonable minds could differ, denied the new-trial motion, and sentenced Acosta to concurrent terms; the Supreme Court affirmed.

Issues

Issue	State's Argument	Acosta's Argument	Held
Whether the trial justice erred in denying a new trial based on the weight of the evidence	Trial justice properly acted as a thirteenth juror, assessed credibility, and found evidence such that reasonable minds could differ	The verdict is against the weight of the evidence; trial justice overlooked/construed evidence improperly	Denied; trial justice applied correct multi-step analysis and denial was not clearly erroneous
Whether Ivy had a motive to fabricate (disclosure of gender/sexuality)	Any potential motive was explored; trial justice considered family estrangement and credibility overall	Acosta argued Ivy was angry after he allegedly disclosed her secret and that provided a motive to lie	Court held trial justice considered motive and did not overlook or misconceive that evidence
Whether lack of independent corroboration required reversal	State argued no corroboration requirement exists for sex-offense prosecutions under Rhode Island law	Acosta argued absence of independent evidence undermines verdict	Rejected: Court reiterated statutory/precedential elimination of corroboration requirement for sex offenses
Whether the trial justice overlooked inconsistencies and other implausibilities raised by defense	State noted extensive cross-examination and that inconsistencies go to credibility, which the judge properly weighed	Acosta argued inconsistencies and implausibilities show verdict was unreliable	Court found trial justice addressed inconsistencies, assessed demeanor and detail, and reasonably concluded verdict could stand

Key Cases Cited

State v. Gumkowski, 223 A.3d 321 (R.I. 2020) (trial justice’s role as thirteenth juror and deference on new-trial motions)
State v. DiCarlo, 987 A.2d 867 (R.I. 2010) (required multi-step analysis for motions for a new trial)
State v. Grantley, 149 A.3d 124 (R.I. 2016) (denial of new trial will stand unless justice overlooked or misconceived material evidence)
State v. Rathbun, 184 A.3d 211 (R.I. 2018) (elimination of independent corroboration requirement in sex-offense cases)
State v. Alexis, 185 A.3d 526 (R.I. 2018) (deference to trial-justice credibility findings)
State v. Johnson, 199 A.3d 1046 (R.I. 2019) (discussion of the trial-justice role in reviewing weight-of-evidence claims)
State v. Banach, 648 A.2d 1363 (R.I. 1994) (record should reflect justice’s reasoning on key points)
State v. Robat, 49 A.3d 58 (R.I. 2012) (trial justice need only cite sufficient evidence to show correct standard applied)