State v. Carpio, 43 A.3d 1

Carpio murdered a Providence police detective with the officer's own firearm after an earlier assault on an elderly woman and a later escape; he was convicted of first-degree murder, discharging a firearm during a crime of violence, and felony assault with a dangerous weapon.
Defendant raised an insanity defense based on mental incapacity; multiple experts testified for both sides on criminal responsibility.
Trial court instructed the jury on Model Penal Code insanity standards and emphasized community standards of blameworthiness in evaluating impairment; jury found guilt beyond a reasonable doubt.
Carpio received life without parole for first-degree murder of a police officer, plus consecutive sentences for the firearm discharge and the elderly-woman assault; the trial judge held he was incorrigible and not rehabilitable.
On appeal, Carpio challenged the insanity instructions and the sentence; the Court denied the appeal in all respects.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Insanity instructions adequacy	Carpio argues the instructions added a second-tier standard.	Carpio contends language about 'community's sense of justice' framed an extra element.	Instructions were proper; no extra element added.
Sufficiency of evidence on criminal responsibility	Carpio asserts evidence supports lack of criminal responsibility.	Carpio argues insufficiency of evidence on insanity defense.	Waived; no review of sufficiency on direct appeal under raise-or-waive rule.
Sentence for murder of a police officer	State supports life without parole given offense and defendant's history.	Carpio seeks reduction to life with parole, citing rehabilitation and mental illness.	Life without parole affirmed; not reduced.
Proper scope of appellate review for insanity questions	N/A	N/A	Rhode Island does not recognize plain-error; raise-or-waive governs.

State v. Johnson, 121 R.I. 254 ((1979)) (adopted Model Penal Code standard for insanity; role of jury as arbiter of responsibility)
State v. Barrett, 768 A.2d 929 ((2001)) (insanity standard and jury's responsibility depend on community standards)
State v. Tassone, 749 A.2d 1112 ((2000)) (life without parole review; independent judicial discretion)
State v. Graham, 941 A.2d 848 ((2008)) (criteria for assessing disproportionate punishment and aggravating factors)
State v. Lynch, 854 A.2d 1022 ((2004)) (sufficiency issues tied to trial motions and preservation)