State v. Cipriano, 21 A.3d 408

Cipriano and Bryant were convicted in Superior Court of receiving stolen goods over $500 and conspiring to commit larceny based on Nicoletti's shoplifting and their alleged involvement.
Nicoletti testified she stole medications and Bath & Body Works products and sold them to Cipriano; police later found thousands of items at Cipriano's home, some matching stolen goods.
Police traced a white van and a gold/white vehicle, CCTV and surveillance linked Cipriano, Bryant, Nicoletti, and others to the thefts, with Bryant driving and Nicoletti signaling the plan.
Evidence included extensive seizure of CVS Bath & Body Works products, prescriptions, and unrelated CVS receipts, plus eBay accounts tied to Cipriano and Bryant used to list stolen merchandise.
Bryant lived at Cipriano's home, kept belongings there, and used Cipriano's address, supporting constructive possession of seized items.
The CVS field manager's retail value of seized items totaled $60,405.20, supporting the sufficiency of the value for the offense charged.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for receipt of stolen goods	Nicoletti proved Cipriano/Bryant received stolen goods.	Items were not individually identified as stolen.	Sufficient evidence (circumstantial plus direct) established receipt of stolen goods.
Sufficiency of evidence for conspiracy to commit larceny	Nicoletti's testimony and defendants' conduct show a conspiratorial plan.	No clear agreement to commit larceny existed.	Evidence supported finding of conspiracy.
Jury instruction on inferences and pyramiding	Trial court adequately instructed on reasonable inferences and proof beyond a reasonable doubt.	Needed specific pyramiding/inference cautions.	No reversible error; instructions adequately stated law and avoided improper pyramiding.
Reasonable doubt instruction and possible misstatement	Standard explained and upheld; any misstatement was corrected.	Misstatement about clear and convincing evidence could mislead jurors.	Any misstatement corrected; reasonable doubt instruction found sufficient.
Motion to pass due to bus testimony implying incarceration	Bus remark not prejudicial to warrant passing.	Remark improperly suggested incarceration, prejudicing trial.	No abuse of discretion; no curative instruction required; motion to pass denied.

State v. Ros, 973 A.2d 1148 (R.I. 2009) (standard for reviewing denial of acquittal)
State v. Caba, 887 A.2d 370 (R.I. 2005) (evidentiary standard for review of acquittals)
State v. Reyes, 984 A.2d 606 (R.I. 2009) (beyond reasonable doubt standard in circumstantial cases)
State v. Cardin, 987 A.2d 248 (R.I. 2010) (standard for evaluating sufficiency of evidence)
State v. Keiser, 796 A.2d 472 (R.I. 2002) (instructional adequacy in jury charges (mem.))
State v. Imbruglia, 913 A.2d 1022 (R.I. 2007) (jury instructions need not use specific words to state law)
State v. Mastracchio, 612 A.2d 698 (R.I. 1992) (conspiracy elements and inferential proof)
State v. Berroa, 6 A.3d 1095 (R.I. 2010) (pyramiding of inferences must avoid speculation)