State v. James Adams
161 A.3d 1182
| R.I. | 2017Background
- In July 2012 police found the decomposed body of Mary S. Grier in a Cranston garage; investigation connected Grier to phone activity and items at the scene. Defendant James Adams was arrested and indicted for Grier’s murder and several related violent offenses arising from separate encounters with two other women (Dyer and Malave) who identified him.
- Forensic evidence: autopsy concluded homicidal violence; extensive decomposition limited precision on cause/timing. DNA testing matched Adams to a major component on underwear found at scene.
- Cell‑phone analysis (FBI CAST agent) placed Adams’s and Grier’s phones in the same approximate vicinity on or about July 15, 2012; MetroPCS/T‑Mobile records were admitted at trial.
- Witnesses placed Adams at the garage in mid‑July 2012; a jailhouse cellmate (Oduntan) testified that Adams made incriminating admissions.
- A jury convicted Adams of second‑degree murder, two counts of felony assault, first‑degree robbery, and unlawful possession of a firearm. The trial justice denied Adams’s Rule 33 motion for a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of FBI cell‑phone expert under Rule 702 | State: agent is qualified; cell‑tower analysis is reliable and helpful to jury | Adams: testimony was novel/unreliable (Daubert concerns) and agent could not pinpoint tower/location with certainty | Admissible — court found field not novel here; expert methodology reliable; limitations go to weight not admissibility |
| Discovery (Rule 16) re: late disclosure of expert | State: provided expert testimony and hearing before trial; defense had opportunity to seek continuance | Adams: one‑month notice insufficient; trial justice should have sanctioned/excluded testimony | No abuse of discretion — trial justice offered remedy/continuance; defense did not request delay; no clear prejudice shown |
| Admission/authentication of MetroPCS records via T‑Mobile witness (business‑records exception & Rule 901) | State: T‑Mobile employee familiar with MetroPCS recordkeeping and procured records; foundation adequate | Adams: records were MetroPCS records, not maintained by T‑Mobile, so witness not proper custodian; authentication lacking | Admissible — trial justice found witness had sufficient familiarity and authentication burden is slight; lay issues of weight go to jury |
| Weight of evidence / sufficiency for new trial (including malice for 2d‑degree murder) | State: combined cell‑phone data, DNA, eyewitnesses, jailhouse admissions, and other testimony supported convictions | Adams: key witnesses (Dyer, Malave, jail informant) unreliable; decomposition made cause/time of death indeterminate; no proof of malice for murder | Trial justice (thirteenth juror) credited testimony (including Oduntan) and found evidence sufficient; denied new trial — appellate court affirmed |
Key Cases Cited
- State v. Mohapatra, 880 A.2d 802 (R.I. 2005) (trial justice has discretion on admissibility of evidence)
- State v. Grayhurst, 852 A.2d 491 (R.I. 2004) (appellate review of evidentiary rulings)
- State v. Evans, 742 A.2d 715 (R.I. 1999) (trial justice’s discretion and supporting record required)
- Morabit v. Hoag, 80 A.3d 1 (R.I. 2013) (trial justice gatekeeper role for expert testimony)
- DiPetrillo v. Dow Chemical Co., 729 A.2d 677 (R.I. 1999) (factors for evaluating novel expert testimony)
- Owens v. Silvia, 838 A.2d 881 (R.I. 2003) (admission of expert testimony and methodological reliability)
- Beaton v. Malouin, 845 A.2d 298 (R.I. 2004) (expert qualification standard)
- State v. Santiago, 81 A.3d 1136 (R.I. 2014) (Rule 16 discovery scope and purpose)
- State v. Rosado, 139 A.3d 419 (R.I. 2016) (factors for addressing discovery violations)
- State v. Briggs, 886 A.2d 735 (R.I. 2005) (Rule 16 and required disclosures)
- McGovern v. Bank of America, N.A., 91 A.3d 853 (R.I. 2014) (low threshold for authentication under Rule 901)
- O’Connor v. Newport Hospital, 111 A.3d 317 (R.I. 2015) (authentication standard and pragmatic approach)
- Rhode Island Managed Eye Care, Inc. v. Blue Cross & Blue Shield of Rhode Island, 996 A.2d 684 (R.I. 2010) (business‑records foundation and persuasive force left to jury)
- State v. Grantley, 149 A.3d 124 (R.I. 2016) (trial justice as thirteenth juror on Rule 33 motions)