State v. Joseph Lamontagne, 231 A.3d 1132

Defendant Joseph Lamontagne was convicted of first‑degree robbery and assault with a dangerous weapon in a dwelling after an altercation at an apartment on December 27, 2015; Cacciato was the only percipient witness.
At trial Cacciato admitted drug use and dealing; Vanmoerkerque testified she saw Lamontagne strike Cacciato with a rock; Cacciato testified Lamontagne attacked and robbed her.
Before and during trial the State moved in limine to exclude four of Cacciato’s prior convictions; two were excluded pretrial and the trial justice later excluded the remaining two (resisting arrest and domestic disorderly conduct) as unduly prejudicial/“pile‑on.”
Lamontagne sought to admit photographs taken January 8, 2016 showing bruises on his torso; the trial justice excluded them for lack of a sufficient nexus to the December 27 incident and because hospital records did not corroborate such injuries.
Lamontagne appealed both evidentiary exclusions; the Rhode Island Supreme Court affirmed the Superior Court, holding no abuse of discretion in excluding the prior convictions or the photographs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of complaining witness’s prior convictions under Rule 609	Exclusion proper: convictions would be cumulative, "pile‑on," some petty; jury already heard drug conduct so convictions unnecessary and unduly prejudicial	Exclusion impaired defendant’s ability to impeach Cacciato on credibility; convictions were probative and any prejudice could be cured by limiting instruction	Affirmed: trial justice did not abuse discretion in excluding convictions given cumulative evidence of illicit conduct and prejudice concerns
Admissibility of defendant’s Jan. 8, 2016 injury photographs/testimony	Exclusion proper: no sufficient temporal or evidentiary nexus to the Dec. 27 incident; hospital record did not corroborate those specific injuries	Photographs are relevant to self‑defense and should go to the jury; nexus and timing affect weight, not admissibility	Affirmed: exclusion not an abuse of discretion because no adequate evidence connected those photos to the charged assault

State v. Gongoleski, 14 A.3d 218 (R.I. 2011) (trial justice has broad discretion to admit or exclude prior convictions for impeachment)
State v. Remy, 910 A.2d 793 (R.I. 2006) (purpose of Rule 609 is to allow jurors to assess witness respect for the law and truthfulness)
State v. McRae, 31 A.3d 785 (R.I. 2011) (appellate court will affirm trial court’s discretionary evidentiary rulings absent abuse)
State v. Whitfield, 93 A.3d 1011 (R.I. 2014) (admission of multiple prior convictions for impeachment may be appropriate when credibility is central)
Wells v. Uvex Winter Optical, Inc., 635 A.2d 1188 (R.I. 1994) (trial court should exercise Rule 403 exclusion sparingly; exclude only when evidence is marginally relevant and enormously prejudicial)
State v. Mercurio, 89 A.3d 813 (R.I. 2014) (admission of prior convictions where case hinges on credibility may be upheld)