State v. Bunnell
47 A.3d 220
| R.I. | 2012Background
- Thomas J. Wright died in Oct. 2004 from extensive blunt-force injuries inflicted by his aunt and her boyfriend after a night out drinking.
- Katherine Bunnell was convicted of second-degree murder and conspiracy to commit murder and sentenced to consecutive life terms plus a 10-year term.
- Appeal challenges (1) exclusion of portions of Delestre’s police interview under Rule 804(b)(3) and (2) denial of a new-trial motion.
- Medical and forensic evidence linked the injuries to blunt-force trauma; autopsy disclosed multiple head and body injuries, including a battered tongue and fractures.
- Trial record showed contemporaneous accounts by Kayla (babysitter) and responders; district police and medical examiner testimony discussed the timing and severity of injuries.
- Superior Court affirmed; Justice Indeglia did not participate.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Rule 804(b)(3) admissibility of Delestre interview | Bunnell argues complete interview should be admitted | State argues portions not sufficiently against penal interest; redaction appropriate | Excerpts redacted; complete interview not admitted |
| Rule 106 completeness doctrine | Completeness rule should apply to Rule 804(b)(3) evidence | Rule 106 not available to the proponent here | Rule 106 not applicable; no completeness rule adopted in this context |
| Motion for new trial credibility assessment | Inconsistencies in Kayla’s testimony undermine verdict | Trial judge independently evaluated credibility; no error | Denied; decision not clearly erroneous |
| Overall sufficiency of evidence supporting murder verdict | Evidence supports malice and causation | Affirmed the conviction | |
| Timeliness/notice of appeal and judicial handling | Not necessary to resolve as to the outcome |
Key Cases Cited
- State v. Lynch, 854 A.2d 1022 (R.I. 2004) (trustworthiness factors for Rule 804(b)(3))
- State v. Pacheco, 763 A.2d 971 (R.I. 2001) (three-factor test for trustworthiness; corroboration matters)
- Williamson v. United States, 512 U.S. 594 (1984) (definition of 'statement' under Rule 804(b)(3); collateral statements not automatically admissible)
- State v. Firth, 708 A.2d 526 (R.I. 1998) (trustworthiness considerations for statements against interest)
- State v. Gaspanco, 694 A.2d 1204 (R.I. 1997) (Rule 106 applicability not available to first introducer of the statement)
- State v. Rodriguez, 996 A.2d 145 (R.I. 2010) (close alignment of RI rules to federal counterparts)
- State v. Cipriano, 21 A.3d 408 (R.I. 2011) (standard for reviewing denial of a new trial)