State v. James Gaffney
63 A.3d 888
| R.I. | 2013Background
- Defendant James Gaffney was charged with two counts of felony assault under G.L. 1956 § 11-5-2; he was found guilty by a jury of the lesser-included simple assault on count 1 and of felony assault causing serious bodily injury on count 2.
- The trial judge denied the defense’s motions for judgment of acquittal and for a new trial after the jury verdict.
- Meneses testified she had spent the day at Gaffney’s Woonsocket apartment, using crack cocaine and alcohol; she suffered a head wound and extensive injuries with no reliable memory of the events.
- Trahan, a neighbor, testified she heard a commotion in the apartment and identified Gaffney’s voice; she observed Meneses being injured and bleeding.
- Medical witnesses described Meneses as critical upon arrival, with head trauma and signs of life-threatening injury; a CT scan showed no brain bleed or neck fracture, but staples were placed in the back of her head.
- The Supreme Court affirmed, holding there was sufficient evidence to convict on felony assault for serious bodily injury, and did not reach the question of whether the injuries constituted serious permanent disfigurement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence proves substantial risk of death under 11-5-2(c)(1). | Gaffney argues no substantial risk of death was shown. | State argues the totality of injuries created substantial risk of death. | Evidence sufficient to support substantial risk of death. |
| Whether the evidence proves serious permanent disfigurement under 11-5-2(c)(3). | State contends Staples caused permanent disfigurement. | Defendant argues no permanent scar or hair loss is proven. | Not reached; court affirmed on sufficiency for the first prong and did not address disfigurement. |
| Whether denial of motions for judgment of acquittal and for a new trial was correct. | State established lawful sufficiency beyond a reasonable doubt. | Evidence insufficient for the charged felony. | Court affirmed the resulting conviction; analysis of judgment of acquittal rendered unnecessary. |
Key Cases Cited
- State v. Pineda, 13 A.3d 623 (R.I. 2011) (standard for reviewing sufficiency of evidence on acquittal/new-trial motions)
- State v. Cardin, 987 A.2d 248 (R.I. 2010) (instruction on reviewing sufficiency and credibility in post-verdict challenges)
- State v. Caba, 887 A.2d 370 (R.I. 2005) (probe of sufficiency standard for judgments of acquittal)
- State v. Clark, 974 A.2d 558 (R.I. 2009) (reaffirmed standard for sufficiency and new-trial review)
- State v. Karngar, 29 A.3d 1232 (R.I. 2011) (clarified de novo review and credibility considerations)
- Paret-Ruiz v. United States, 567 F.3d 1 (1st Cir. 2009) (federal standard for reviewing sufficiency on appeal)
- State v. Lynch, 854 A.2d 1022 (R.I. 2004) (weight-of-the-evidence standard in new-trial claims)
- State v. Colbert, 549 A.2d 1021 (R.I. 1988) (foundational analysis for new-trial sufficiency review)