State v. Elton G. Edwards
147 A.3d 982
| R.I. | 2016Background
- On August 22, 2008, Providence police stopped Elton G. Edwards after observing risky driving; officers Fernandes and Reposa approached his vehicle. Edwards, a passenger Danika Rollins, and her aunt Carol were in the car. A physical altercation occurred after Edwards exited the vehicle.
- Officers alleged Edwards verbally abused Fernandes, exited the car, lunged at Fernandes, and bit Officer Reposa in multiple locations; officers used baton strikes and pepper spray and transported Edwards to the hospital. Photographs and medical records documented injuries to the officers and to Edwards.
- Edwards and Danika gave a conflicting account: they claimed officers used excessive force, pulled Edwards from the car, beat him, and that Edwards did not bite officers. Danika also alleged officer racial slurs and inconsistent descriptions of events.
- Blood drawn at the hospital tested at .097% ethanol (above the statutory .08% limit). Officer Reposa (deceased by unrelated event) did not testify at trial; Fernandes and other officers did.
- Edwards waived a jury; after a two-day bench trial the trial justice convicted him of five counts: felony assault on a police officer, simple assault, resisting arrest, DUI, and obstructing an officer. Sentence was imposed but execution was stayed pending appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard of review / credibility | Trial justice’s credibility findings should be afforded deference; record contains competent evidence supporting convictions | Trial justice misconceived/overlooked material evidence and erred in credibility assessments | Affirmed: appellate court defers to trial justice unless findings are clearly wrong or material evidence was overlooked |
| Sufficiency of evidence for felony assault on officer | Fernandes’ testimony, medical photos/records, and injuries support that Edwards assaulted and bit Officer Reposa | Edwards denied biting or striking officers and claimed he was beaten by officers | Affirmed: trial justice credited officer testimony and physical evidence; felony-assault conviction supported by competent evidence |
| Sufficiency of evidence for DUI | Blood test (.097%), officer observations (odor, red/watery eyes), and testimony placing Edwards at a party support DUI conviction | Edwards claimed limited drinking (one or two beers) and contested circumstances of stop and treatment | Affirmed: blood-alcohol result and observational evidence satisfied elements beyond a reasonable doubt |
| Claim that trial justice overlooked excessive-force evidence and conflicting witness statements | Edwards argued officers fabricated account to hide excessive force; trial justice ignored inconsistencies and other exculpatory evidence | Trial justice considered inconsistencies, credited officers over defense witnesses, and relied on medical records, photos, and blood results | Affirmed: appellate court found trial justice thoroughly reviewed the record, noted defense inconsistencies, and reasonably rejected defense testimony |
Key Cases Cited
- State v. Van Dongen, 132 A.3d 1070 (R.I. 2016) (deference to trial justice credibility findings)
- State v. Adewumi, 966 A.2d 1217 (R.I. 2009) (appellate review standard for factual findings)
- State v. Forand, 958 A.2d 134 (R.I. 2008) (appellate court must ensure record contains sufficient evidence to support findings)
- State v. Erminelli, 991 A.2d 1064 (R.I. 2010) (trial-judge advantage in observing witness demeanor)
- South County Post & Beam, Inc. v. McMahon, 116 A.3d 204 (R.I. 2015) (appellate review will not substitute its view when competent evidence supports trial court)