State v. Jaylon Baker
79 A.3d 1267
R.I.2013Background
- Defendant Jaylon Baker (17 at the time) was tried in Superior Court as an adult for assault with a dangerous weapon, carrying a pistol without a license, and using a firearm while committing a crime of violence arising from a July 17, 2010 foot chase and shooting by Ptlm. David Allen.
- Patrolman Allen chased two males from Comstock toward Harvard/Wesleyan Avenues, saw what he identified as a Ruger .22 in Baker’s hand, ordered them to drop the gun, and fired at Baker while running; Baker was shot in the right arm and later captured caught on a fence.
- Police recovered a Ruger .22 with an obliterated serial number and .40-caliber shell casings near 40 Harvard; no .22 shell casings or usable prints were recovered from the Ruger.
- Eyewitness accounts conflicted: Parrott (friend) initially told police he saw Baker with a gun; at trial he equivocated. Two civilian witnesses testified they did not see a gun. Baker testified he did not have a gun and was shot while fleeing.
- Jury convicted Baker on counts of assault with a dangerous weapon, carrying a handgun without a license, and using a firearm during a crime of violence. Baker moved for a new trial arguing the trial justice misconceived material evidence and Allen’s testimony was not credible; the trial justice denied the motion and imposed consecutive sentences.
Issues
| Issue | State's Argument | Baker's Argument | Held |
|---|---|---|---|
| Whether the trial justice erred in denying a new-trial motion by failing to credit contrary evidence | The trial justice properly weighed credibility and physical evidence supporting Ptlm. Allen; jurors could assess disputed testimony | Allen’s account is inconsistent with physical evidence and witnesses; impossible he didn’t see Baker discard the gun or that Baker scaled fences after being shot | Trial justice did not overlook or misconceive material evidence; denial affirmed |
| Whether credibility determinations (Allen vs. Baker and other witnesses) were properly made by trial justice | Trial justice, as thirteenth juror, permissibly credited Allen and portions of Parrott’s pretrial statement over trial equivocations | Trial justice should have discredited Allen and relied on civilians who saw no gun | Trial justice acted within discretion in assessing credibility and weight of evidence |
| Whether physical evidence (bullet hole trajectory, location of gun, shell casings) contradicted Allen’s account | Physical evidence (recovered Ruger, .40 casings, scene photos, jury view) was consistent with Allen’s testimony | Trajectory and locations show inconsistency with Allen’s stated shooting positions and timeline | Court found physical evidence consistent with Allen and insufficient to overturn verdict |
| Whether possible motive for fabrication (planting gun or self-protection) required new trial | State: no corroborating evidence of planting; inconsistencies explained by common factors; jury saw all evidence | Baker: Allen had motive to fabricate to justify shooting; gun could be “planted” or communal | Speculation about motive without supporting evidence insufficient to disturb trial justice’s credibility findings |
Key Cases Cited
- State v. LaPierre, 57 A.3d 305 (R.I. 2012) (trial justice acts as thirteenth juror on new-trial motions and must articulate reasons for accepting or rejecting verdict)
- State v. Bunnell, 47 A.3d 220 (R.I. 2012) (trial-justice new-trial review standard; appellate review is deferential when trial justice articulates adequate grounds)