State v. Christopher S. Thornton
2013 R.I. LEXIS 106
R.I.2013Background
- Christopher S. Thornton was convicted in 1997 of kidnapping, assault-related offenses, witness intimidation, and violating a no-contact order; convictions previously affirmed on direct appeal and an earlier postconviction application.
- In 2009–2010 Thornton filed pro se and then counsel-filed postconviction motions asserting (1) double-jeopardy errors and (2) nondisclosure of victim-impact statements (Brady/Rule 16) and seeking a new trial based on newly discovered evidence.
- The state had not formally produced three victim-impact statements to Thornton before trial, but those statements were filed with the clerk and noted on the docket; the state characterized nondisclosure as inadvertent.
- At postconviction hearings the state produced the victim-impact statements; Thornton asserted they contained impeachment or exculpatory information he could have used at trial.
- The hearing justice denied relief, finding Thornton’s double-jeopardy claim meritless, the victim-impact statements were immaterial or cumulative (no Brady prejudice), nondisclosure was not deliberate (so Stravato did not require presumed prejudice), and the statements were discoverable earlier (res judicata / not newly discovered).
- The Supreme Court affirmed, applying Brady/Bagley materiality, Rule 16 principles (and Stravato distinction), res judicata, and the standard for newly discovered evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether nondisclosure of victim-impact statements violated Brady (materiality) | Thornton: statements contained impeachment/exculpatory material that would have changed the verdict | State: statements were immaterial or cumulative; no reasonable probability of a different outcome | Held: No Brady violation — Thornton failed to show reasonable probability of different result (Bagley standard) |
| Whether nondisclosure violated Rule 16 and warrants new trial under Stravato | Thornton: Rule 16 required production; nondisclosure prejudiced defense | State: nondisclosure was inadvertent, not deliberate; Stravato (which presumes prejudice when nondisclosure is deliberate) does not apply | Held: No relief under Rule 16 — nondisclosure was not deliberate and no prejudice shown |
| Whether claim is barred by res judicata | Thornton: argued claim on postconviction grounds now | State: Thornton, through counsel on prior proceedings, should have known of statements; claim was available earlier | Held: Res judicata applies — Thornton could have raised the issue earlier (and claim also lacks merit) |
| Whether victim-impact statements qualify as newly discovered evidence for a new trial | Thornton: he never saw the statements until 2010 and they are newly discovered | State: statements were docketed/available and discoverable earlier with due diligence | Held: Not newly discovered — claim fails under the standard for new-trial evidence |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose favorable material evidence that is material to guilt or punishment)
- United States v. Bagley, 473 U.S. 667 (1985) (Brady materiality standard: reasonable probability sufficient to undermine confidence in outcome)
- State v. Stravato, 935 A.2d 948 (R.I. 2007) (deliberate withholding of victim-impact statement warrants presumed prejudice and new trial)
- Blockburger v. United States, 284 U.S. 299 (1932) (same-offense test for double jeopardy)
- State v. Thornton, 800 A.2d 1016 (R.I. 2002) (prior direct-appeal decision affirming Thornton’s convictions)