State v. Gauthier
15 A.3d 1004
| R.I. | 2011Background
- Gauthier pled guilty in 2002 to entering a dwelling with felonious intent; sentenced to 10 years with 2 to serve, 8 suspended with probation.
- In 2007, he pled nolo contendere to felony assault; sentenced to 9 years with 2 to serve, 7 suspended with probation.
- Released from prison July 12, 2008; arrested July 31, 2008 for allegedly assaulting John Simms, a fellow homeless man.
- State filed Rule 32(f) probation-violation report alleging violations of both probations; October 3, 2008 hearing held in Superior Court.
- Hearing: Simms testified of an assault; Officer LaForest testified; credibility concerns acknowledged; judge found reasonably satisfactory evidence of a violation and revoked part of probation, sentencing four years on the 2002 suspended sentence.
- Defendant appealed; an initial appeal was defective, leading to a petition for writ of certiorari granted by this Court in 2010.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there sufficient evidence to prove probation violation? | Gauthier claims the evidence was dubious and credibility-laden. | State contends there was reasonably satisfactory evidence supporting the violation. | Yes; evidence was reasonably satisfactory and not arbitrarily found. |
| Did the court properly assess credibility in a probation-violation context? | Gauthier argues trial court erred in crediting LaForest over Simms. | State argues credibility determinations are for the hearing justice and supported by corroboration. | Courts defer to the hearing justice's credibility determinations when supported by the record. |
| What standard governs probation-violation findings on review? | Gauthier challenges the lower evidentiary threshold as misapplied. | State relies on 'reasonably satisfactory' evidence standard under Rhode Island law. | Standard is 'reasonably satisfactory' evidence; review is for arbitrariness or capriciousness. |
Key Cases Cited
- State v. Christodal, 946 A.2d 811 (R.I.2008) (probaton-violation standard and review framework)
- State v. Bouffard, 945 A.2d 305 (R.I.2008) (lower burden of proof at probation-violation hearings)
- State v. Sylvia, 871 A.2d 954 (R.I.2005) (credibility and weighing evidence in probation context)
- State v. Rioux, 708 A.2d 895 (R.I.1998) (standard for reviewing credibility determinations)
- State v. Pena, 791 A.2d 484 (R.I.2002) (proof standard at probation-violation hearing)
- State v. Johnson, 899 A.2d 478 (R.I.2006) (deference to trial court credibility findings)