State v. John Ford, 56 A.3d 463

Defendant John Ford of RI pled nolo contendere in 2005 to possession of a stolen vehicle/parts and reckless driving; concurrent probation sentences with 102 months suspended.
In 2010, Bartholomew, Ford's girlfriend, alleged domestic assault leading to a probation-violation petition filed by the State.
The violation hearing centered on conflicting accounts of events on October 27, 2010; photographs supported Bartholomew’s account.
Ford sought to introduce an eight-page letter from Bartholomew to impeach credibility and show remorse; the letter was excluded.
The hearing justice credited Bartholomew’s testimony over Ford’s and found a probation violation, imposing 30 months at the ACI; Ford appealed.
The Rhode Island Supreme Court affirmed, applying deferential review of witness credibility and limited evidence standard for probation violations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the letter was rightly excluded at the violation hearing.	State contends letter lacks substantive relevance and impeachment purpose was not preserved.	Ford argues the letter was relevant for impeachment and substantive context.	Letter exclusion affirmed; not abused discretion.
Whether testimony about prior drug-related disputes and past arguments was properly limited.	State maintains past incidents were not directly relevant to the immediate violation.	Ford asserts broader admissibility under Chartier principles.	Testimony properly limited; no abuse of discretion.
Whether the evidence supports the violation finding given credibility determinations.	State needed reasonably satisfactory evidence of violation.	Ford challenges credibility assessment as arbitrary.	Credibility-based finding supported; no arbitrary or capricious error.
Whether raise-or-waive rules bar Ford’s substantive argument about the letter.	State argues raise-or-waive limits scope of appellate review.	Ford contends substantive relevance should be considered.	Raised-the-issue rule waived substantive argument; no error.

State v. English, 21 A.3d 403 (R.I. 2011) (probation-violation standard and deference to credibility)
Bouffard, 945 A.2d 305 (R.I. 2008) (lower burden of proof in probation violations)
Kennedy, 702 A.2d 28 (R.I. 1997) (probation-revocation not a full criminal trial)
Gaspar, 982 A.2d 140 (R.I. 2009) (trial court evidentiary discretion on admissibility)
Chartier, 619 A.2d 1119 (R.I. 1993) (Rule 404(b) admissibility when acts are interwoven with offense)
Jackson, 966 A.2d 1225 (R.I. 2009) (deferential review of credibility determinations in probation cases)
DiChristofaro, 842 A.2d 1075 (R.I. 2004) (probation-violation evidence standards)
Tetreault, 973 A.2d 489 (R.I. 2009) (probation may be revoked for offense even after acquittal)