State v. Guerra
12 A.3d 759
| R.I. | 2011Background
- Guerra was charged with entering O. Ahlborg & Sons on Oct. 10, 2005 with intent to commit larceny and with larceny of two laptops valued over $500.
- A May 2008 jury trial acquitted him on count 2 but convicted on count 1.
- Evidence included Ahlborg’s Columbus Day observations and subsequent identifications (photo array and in-court ID).
- Rowley testified to a May 2006 incident where Guerra allegedly entered the building; a license plate matching Y205566 was noted.
- Detective Duffy linked the photo array to Guerra; a stipulation stated Guerra operated the same car in Oct. 2005 and May 2006.
- Guerra moved for a new trial arguing lack of felonious intent and logical inconsistency of the verdict; the trial court denied the motion; the Rhode Island Supreme Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was sufficient felonious intent to convict | Guerra contends insufficient evidence | Guerra asserts no felonious intent shown | No clear error; evidence supported intent verdict |
| Whether the verdict was logically inconsistent | State argues verdict aligns with evidence | Guerra argues inconsistency between count 1 and count 2 | Verily logical; not grounds to overturn |
Key Cases Cited
- State v. DiCarlo, 987 A.2d 867 (R.I.2010) (thirteenth juror approach for new-trial review)
- State v. Adefusika, 989 A.2d 467 (R.I.2010) (standards for reviewing credibility and weight of evidence)
- State v. Imbruglia, 913 A.2d 1022 (R.I.2007) (independent evaluation of evidence on new-trial motion)
- State v. Morales, 895 A.2d 114 (R.I.2006) (three-step analysis for new-trial decisions; reasonable minds may differ)
- State v. Banach, 648 A.2d 1363 (R.I.1994) (requirement to articulate reasoning in new-trial decisions; appellate deferential review)
- State v. Texeira, 944 A.2d 132 (R.I.2008) (great weight given to trial judge's ruling when properly reasoned)