State v. Joseph Segrain, 243 A.3d 1055

In 2012 Segrain pled nolo contendere to possession of marijuana with intent to distribute and was sentenced to 10 years — 1 year to serve and 9 years suspended with probation.
On January 9, 2017, following a hostile encounter in Courtroom 10 between rival gang members, shots were fired; Mathew DePina was seriously injured.
Witnesses (court security, an attorney, multiple witnesses, and a teenage eyewitness) testified at a Rule 32(f) probation-violation hearing that Segrain drove a BMW alongside DePina’s car and fired into it.
The hearing justice found Segrain violated probation and, after considering several sentencing factors, ordered execution of the remaining nine years of the suspended sentence.
Segrain appealed, arguing the hearing justice relied solely on the new charges (the January 2017 conduct) and failed to give proper weight to the underlying 2012 conviction and other mitigating facts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether executing the full suspended sentence was improper because the hearing justice relied solely on new charges	The State: the hearing justice permissibly considered both the 2012 conviction and the severity of the new conduct as relevant to rehabilitation and sentencing	Segrain: the hearing justice focused only on the pending new charges and did not adequately consider the original offense or mitigating facts	Court affirmed — hearing justice considered multiple appropriate factors and did not abuse discretion; severity of new conduct may inform rehabilitation and sentencing
Whether the case is controlled by State v. Fortes such that the sentence was excessive because it was unduly influenced by the new offense	The State: Fortes is distinguishable; the original offense here was itself serious and the hearing justice balanced several factors	Segrain: Fortes requires reversal where the revocation sentence is unduly driven by the subsequent offense’s seriousness	Court affirmed — Fortes distinguished; record shows the hearing justice considered the 2012 offense, the new conduct, rehabilitation prospects, and other sentencing factors

State v. D’Amico, 200 A.3d 1068 (R.I. 2019) (Rule 32(f) requires proof by a fair preponderance)
State v. McKinnon-Conneally, 101 A.3d 875 (R.I. 2014) (hearing justice has wide discretion to execute suspended sentence upon probation breach)
State v. Parson, 844 A.2d 178 (R.I. 2004) (suspended term hangs on good behavior; breach permits execution)
State v. Fortes, 330 A.2d 404 (R.I. 1975) (reversal where revocation sentence was excessive and unduly influenced by the subsequent offense)
State v. Simpson, 174 A.3d 1238 (R.I. 2018) (court may consider severity of new conduct when assessing rehabilitation)
Neufville v. State, 172 A.3d 161 (R.I. 2017) (same — consideration of subsequent conduct relevant to revocation sentencing)
State v. Prout, 116 A.3d 196 (R.I. 2015) (trial court weighs evidence and assesses witness credibility at probation revocation)
State v. Washington, 42 A.3d 1265 (R.I. 2012) (appellate deference to trial judge’s credibility assessments)