State v. José Angeles, 157 A.3d 27

On July 6, 2011, Sgt. Gregory Sion (Providence PD narcotics) observed a silver SUV driving aggressively; after a confrontation the SUV fled and later crashed; defendant José Angeles was arrested after fleeing on foot.
After arrest, Officer Andres Perez recovered from the driver’s-side floor a clear plastic bag containing nine individually wrapped bags of suspected crack cocaine; defendant later stipulated to admission of the cocaine and toxicology report.
Defendant moved pretrial to suppress the cocaine, arguing the stop/arrest and subsequent seizure were unlawful; the trial justice held a suppression hearing and denied the motion.
At trial, defense cross-examination and witness testimony referenced plain-view, probable cause, and the earlier suppression hearing.
In jury charge, the trial justice told jurors the legality of the seizure was a legal issue he (the judge) had decided at the suppression hearing and was not for the jury to decide; he also instructed jurors they could consider witness credibility but not legal determinations about the seizure.
Defendant petitioned this Court for certiorari (having missed the direct-appeal window), claiming the jury instruction impermissibly commented on the evidence and improperly bolstered the State. The Supreme Court affirmed the conviction.

Issue	State's Argument	Angeles's Argument	Held
Whether the trial justice’s jury instruction—stating the legality of the cocaine seizure was a legal issue he decided after a prior suppression hearing—constituted an improper comment on the evidence or otherwise confused/bolstered the State	The instruction correctly and clearly told jurors that the legality of the search/seizure was a legal matter for the judge, not the jury; mentioning the suppression hearing provided necessary context and did not mislead.	The instruction went beyond a neutral admonition and communicated that the judge had already decided the seizure in the State’s favor, thereby commenting on the evidence and bolstering the State.	The Court held the instruction was proper. Read in the context of the full charge, it did not disclose the judge’s ruling in a prejudicial way, did not comment on the evidence, and would not have misled a jury of ordinary intelligence.

State v. Pona, 66 A.3d 454 (R.I. 2013) (de novo review of jury-instruction issues and instructions need only adequately cover the law)
State v. Vargas, 991 A.2d 1056 (R.I. 2010) (standards for reviewing jury instructions)
State v. Sivo, 809 A.2d 481 (R.I. 2002) (jury instructions must adequately cover the law)
State v. Imbruglia, 913 A.2d 1022 (R.I. 2007) (jury instructions assessed by how ordinary intelligent jurors would understand them and examined in context)
State v. John, 881 A.2d 920 (R.I. 2005) (same principle regarding jury comprehension)
Saber v. Dan Angelone Chevrolet, Inc., 811 A.2d 644 (R.I. 2002) (reversal for erroneous jury charge requires showing jury could have been misled to the party's prejudice)
Patino v. Suchnik, 770 A.2d 861 (R.I. 2001) (standard for prejudicial effect from jury instruction error)