State v. Joseph Ogoffa, 159 A.3d 1043

Defendant Joseph Ogoffa was indicted in 2008 and convicted in January 2014 of five counts of first‑degree child molestation based on the testimony of the complainant (identified as "Sarah") about five incidents occurring when she was six.
Sarah testified at trial (age 18) about two incidents of penile‑vaginal penetration and three incidents of digital vaginal penetration; medical exam at Child Safe Clinic was essentially normal but noted a possible loss of tissue suggestive (not definitive) of penetrating trauma.
Sarah delayed reporting until age 12 when she told a cousin; her mother and police were later notified and the Clinic Note (entered into evidence) recorded an earlier statement that the assault included anal penetration 3–5 times.
Defendant moved for a new trial arguing the verdict was against the weight of the evidence, pointing to inconsistencies in Sarah’s statements, alleged improbabilities, and alleged motive to fabricate.
Defendant also argued his right to present a full defense was violated because the trial justice limited cross‑examination of two witnesses (the mother, Cathy, and cousin, Leslie) regarding prior statements.
The trial justice denied the new‑trial motion after acting as a thirteenth juror, finding the complainant credible and that the verdicts were supported; the Supreme Court granted certiorari and affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Ogoffa)	Held
Whether the trial justice erred in denying a new trial based on the weight of the evidence	Jury verdict should stand; trial justice properly reviewed credibility and evidence and found complainant credible	Inconsistencies, improbabilities, lack of physical findings, and an alleged motive to fabricate render verdicts against the weight of the evidence	Denial of new trial affirmed — trial justice applied the three‑step test, assessed credibility, and reasonably deferred to jury where reasonable minds could differ
Whether limiting cross‑examination denied defendant a constitutional right to present a full defense	Trial court reasonably sustained objections and allowed sufficient cross‑examination; Clinic Note was admitted and available to jury	Trial court unfairly prevented impeachment of mother with Clinic Note statement and curtailed questioning of cousin about the complainant’s ability to identify the perpetrator	No abuse of discretion; limitations were minor, consistent‑statement determination was reasonable, and defendant’s right to a meaningful opportunity to present a defense was not violated

State v. Barrios, 88 A.3d 1123 (R.I.) (trial justice acts as thirteenth juror on new‑trial motion)
State v. Muralles, 154 A.3d 925 (R.I.) (three‑step test for new‑trial weight review and required articulation)
State v. Cianci, 430 A.2d 756 (R.I.) (trial court must determine whether a prior statement is truly inconsistent and material)
State v. Walsh, 731 A.2d 696 (R.I.) (trial court’s discretion in limiting cross‑examination reviewed for abuse)
State v. Vargas, 991 A.2d 1056 (R.I.) (latitude afforded to trial justices on witness examination)
State v. Bojang, 83 A.3d 526 (R.I.) (defendant has right to effective cross‑examination though not absolute)
State v. Tiernan, 941 A.2d 129 (R.I.) (unduly restrictive cross‑examination can violate right to expose bias and deny fair trial)