State v. Chaquiro Blandino, 171 A.3d 21

On May 2, 2014 Chaquiro Blandino shot and killed Francis Rodriguez; Blandino was convicted by a jury of first-degree murder and related offenses and received consecutive life and fixed prison terms.
Blandino’s defense was that he acted in self-defense after associates of the C-Block gang (Rodriguez and witness Marvin Vasquez) threatened him and that Vasquez pointed a gun at him.
State evidence included ballistic testing showing multiple casings near the speed hump, projectiles in Rodriguez’s Subaru (including one in the glove compartment), and a fatal bullet trajectory entering the back of Rodriguez’s neck and exiting through his eye.
Detective Angelo A’Vant investigated, recovered a .40-caliber firearm near defendant’s residence, and had investigatory notes which defense counsel requested at trial.
The trial justice denied defense access to A’Vant’s investigatory notes after the prosecutor objected under Rule 16; defense did not expressly raise Brady or Rule 16 arguments at the trial-level ruling.
Blandino moved for a new trial; the trial justice, acting as a thirteenth juror, rejected Blandino’s credibility and self-defense theory based on witness inconsistencies and perceived mismatch between Blandino’s account and the physical/ballistic evidence.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Blandino)	Held
Whether Detective A’Vant’s investigatory notes had to be produced under Rule 16 or Brady	State: investigative notes are not required under Rule 16; relevant testimony and reports were provided; notes not shown to contain Brady material	Blandino: notes could contain exculpatory or impeachment material (gang association of victims/witness, reputation as a snitch) critical to self-defense theory	Court: Issue not preserved (defense did not raise Brady/Rule 16 at trial); alternatively, notes were not shown to contain Brady material and Rule 16 did not mandate their disclosure
Whether the trial justice erred in denying motion for new trial (credibility, ballistics, witness inconsistencies)	State: trial evidence and ballistic/forensic findings supported jury verdict; trial justice properly assessed credibility	Blandino: trial justice overlooked material evidence and miscredited Vasquez over Blandino/Pineda; ballistic evidence consistent with Blandino’s account	Court: trial justice followed required three-step review, reasonably discredited defense witnesses, found physical evidence inconsistent with self-defense, and did not err in denying new trial

Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose materially exculpatory or impeachment evidence)
DeCiantis v. State, 24 A.3d 557 (R.I. 2011) (state discovery obligations can extend beyond Rule 16 in aid of confrontation)
State v. Briggs, 886 A.2d 735 (R.I. 2005) (Rule 16’s discovery obligations for witness statements)
State v. Chalk, 816 A.2d 413 (R.I. 2002) (right to evidence that aids effective cross-examination arises under confrontation clause)
State v. Yon, 161 A.3d 1118 (R.I. 2017) (preservation/raise-or-waive rule for appellate review)
State v. Moore, 154 A.3d 472 (R.I. 2017) (standard and three-step analysis for trial-justice review of motion for new trial)