State v. Gary Gaudreau
139 A.3d 433
R.I.2016Background
- Gym fire at Physique Gym in Pawtucket during blizzard conditions (Mar. 2, 2009) led to arson charges against owner Gary Gaudreau.
- Two trials: first trial (2012) ended in mistrial; second trial (2013) led to conviction for first-degree arson.
- Prosecution admitted videotaped custodial interrogation; defense challenged its admissibility and potential prejudice under Rhode Island evidence rules.
- Investigators' evidence included accelerant-detecting dog alerts at the scene, recovered fanny pack with loaded handgun, and eyewitness testimony identifying Gaudreau’s jacket/scarf.
- Gaudreau asserted an alternate theory—stockpiled insurance scheme; his own testimony attacked as incredible; witnesses contradicted his timeline and finances.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of videotaped interrogation and detectives’ comments | State | Gaudreau; comments are irrelevant/prejudicial credibility testimony | Harmless error; admissible with caveats; not reversible error |
| Trial court denial of motion for new trial on weight of the evidence | State | Gaudreau; insufficient linkage to accelerant evidence | No error; verdict supported by overwhelming evidence |
Key Cases Cited
- State v. Diaz, 654 A.2d 1195 (R.I. 1995) (interrogation context and admissibility reasoning cited by trial court)
- Elnicki, 105 P.3d 1224 (Kan. 2005) (prohibition on credibility testimony in taped interrogations; redaction issues)
- Kitchen, 730 A.2d 513 (Pa. Super. Ct. 1999) (police credibility comments; need for Rule 403/105 balancing)
- Lanham v. Commonwealth, 171 S.W.3d 14 (Ky. 2005) (limiting admonition as remedy for police-credibility comments)
- Demery, 30 P.3d 1278 (Wash. 2001) (officer credibility comments; admissibility contested; context)
- Sweet v. State, 234 P.3d 1193 (Wy. 2010) (prejudice vs. probative value of police comments in interrogation)
- State v. Rushlow, 32 A.3d 892 (R.I. 2011) (prejudicial effect review of credibility testimony)
- State v. Gomes, 764 A.2d 125 (R.I. 2001) (prejudice assessment for improper statements)
- State v. Ceppi, 91 A.3d 320 (R.I. 2014) (harmless-error standard for improperly admitted evidence)
- State v. Hak, 963 A.2d 921 (R.I. 2009) (general principle that all admissible evidence is prejudicial)
- State v. Mattatall, 603 A.2d 1098 (R.I. 1992) (credibility assessment when defendant testifies)