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135 A.3d 1192
R.I.
2016
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Background

  • Defendant Donald Greenslit was indicted for first-degree murder, failure to report a death to conceal a crime, obstruction of a firefighter, and violation of a no-contact order after remains of victim Stacie Dorego were found at 16 Pershing Road. A jury convicted him on all counts; he was sentenced to life plus consecutive terms on other counts.
  • Key testimonial evidence: a jailhouse detainee (Alex Boisclair) said Greenslit admitted stabbing Dorego and had discussed planning for the children after discovering alleged infidelity; Boisclair related details that were not publicly known.
  • Neighbors and firefighters testified that on January 22, 2012, smoke filled the home, defendant behaved nervously and blocked firefighters trying to enter, and firefighters later found the victim’s remains in the basement.
  • Defendant made a phone call around Christmastime to the victim’s sister expressing concern about the children and indicating they would be taken care of; another friend testified Greenslit said the victim had left with a boyfriend and discussed moving into the house.
  • The trial justice, acting on defendant’s motion for a new trial, applied the three-step weight-of-evidence analysis (consider evidence against the charge, independently assess credibility/weight, decide whether she would reach a different result) and found the witnesses credible and the evidence sufficient; she denied the motion.

Issues

Issue State's Argument Greenslit's Argument Held
Sufficiency of evidence of premeditation for 1st-degree murder Evidence (Boisclair admissions, timing of phone call, pre-death planning) shows appreciable time for premeditation Acts after the killing showed impaired or volatile state; any intent was fleeting/contemporaneous, not premeditated Court affirmed trial justice: evidence supports premeditation and 1st-degree murder conviction
Obstruction of firefighter Defendant’s repeated presence at basement stairs and physical blocking impeded firefighters’ duties He was not explicitly told he could not reenter; his mere presence did not actually hinder firefighting Court affirmed trial justice: defendant’s conduct obstructed and impeded firefighters, supporting conviction
Trial justice’s exercise of new-trial review Trial justice followed required three-step analysis and credited witnesses Defendant argued trial justice erred in weight assessment Court found trial justice complied with standard and did not misconceive material evidence
Credibility of jailhouse informant (Boisclair) His testimony corroborated by nonpublic details and other evidence; thus credible Defense attacked his motives and credibility Trial justice found Boisclair credible; appellate court accepted that finding

Key Cases Cited

  • State v. Hie, 93 A.3d 963 (R.I. 2014) (describing trial-justice role as a "thirteenth juror" and three-step weight-of-evidence analysis)
  • State v. Gonzalez, 56 A.3d 96 (R.I. 2012) (explaining the three-step inquiry and deference to trial-justice credibility findings)
  • State v. Adefusika, 989 A.2d 467 (R.I. 2010) (same standard for new-trial weight review)
  • State v. Gillespie, 960 A.3d 969 (R.I. 2008) (distinguishing first- and second-degree murder based on duration of intent)
  • State v. Rodriguez, 822 A.2d 894 (R.I. 2003) (clarifying premeditation requires appreciable time, not merely a momentary intent)
  • DeFusco v. Brophy, 311 A.2d 286 (R.I. 1973) (defining "obstruction" to include hindering or impeding duties without direct force)
Read the full case

Case Details

Case Name: State v. Donald Greenslit
Court Name: Supreme Court of Rhode Island
Date Published: Mar 11, 2016
Citations: 135 A.3d 1192; 2016 WL 931885; 2016 R.I. LEXIS 35; 2013-290-C.A.
Docket Number: 2013-290-C.A.
Court Abbreviation: R.I.
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