State v. Joseph Segrain
18-144
| R.I. | Jun 24, 2021Background
- January 9, 2017 drive-by shooting after a courthouse confrontation; defendant Joseph Segrain was indicted on multiple firearm and related charges.
- Geovanni Perez (a valet) twice encountered and later identified the BMW driver; police first showed a single photo “show-up,” then a sequential photo array; Perez also made an in-court ID.
- First trial (Jan 2018) was aborted after a witness referenced a prior "violation hearing;" the trial justice initially denied a mistrial, gave a cautionary instruction, then granted a mistrial.
- Second trial was aborted amid defendant’s courtroom misconduct, pro se requests, a contempt finding (later purged), and a decision to start a new trial; jeopardy had not attached to that empaneled jury.
- Third trial proceeded; a jury convicted Segrain on multiple counts; the trial justice sentenced him. Segrain appealed raising double jeopardy, suppression of ID, recusal, self-representation, and evidentiary objections.
Issues
| Issue | State's Argument | Segrain's Argument | Held |
|---|---|---|---|
| Double jeopardy / first mistrial | Claim waived because Segrain failed to move to dismiss under Super. R. Crim. P. 12(b)(2) before trial; no preserved claim | Trial justice sua sponte granted mistrial after misleading jury instruction; Segrain never consented, so retrial violated Fifth Amendment | Claim not preserved under Rule 12(b)(2); Court declined to reach merits and affirmed (no relief) |
| Suppression of eyewitness ID (Perez) | ID was reliable under Neil v. Biggers factors; Perez had independent, detailed recollection and professional aptitude remembering faces/cars | Single-photo show-up before photo array was unnecessarily suggestive and tainted later ID | Trial justice found ID reliable under totality of circumstances; denial of suppression affirmed |
| Motion to recuse trial justice | No showing of personal bias or settled opinion; record lacks grounds for recusal | Judge biased due to contempt finding, denial of continuance, coercion regarding mistrial and discouraging pro se status | Denial of recusal affirmed; no legally sufficient showing of personal bias or prejudice |
| Right to self-representation (trial and sentencing) | Faretta waiver must be voluntary, knowing, intelligent; trial justice adequately warned defendant and found waiver invalid for sentencing | Defendant sought to proceed pro se and was prevented from preparing his defense and denied self-representation at sentencing | Court held trial justice did not err: defendant had at times proceeded pro se at trial but waiver for sentencing was not voluntary/knowing; denial for sentencing affirmed |
| Evidentiary rulings (composite video; rebuttal testimony) | Videos and PowerPoint were authenticated at trial and admitted without objection; rebuttal witness admissible for impeachment | Composite videotape lacked authentication/chain of custody; rebuttal officer’s testimony improperly revealed incarceration and required cautionary instruction | Issues waived/not preserved (no timely objections or requested cautionary instruction); evidentiary rulings sustained |
Key Cases Cited
- Neil v. Biggers, 409 U.S. 188 (1972) (sets factors to assess reliability of eyewitness identifications)
- Faretta v. California, 422 U.S. 806 (1975) (constitutional right to self-representation)
- McKaskle v. Wiggins, 465 U.S. 168 (1984) (limits on standby counsel and pro se control of defense)
- State v. Day, 925 A.2d 962 (R.I. 2007) (timely Rule 12(b)(2) double jeopardy motion required)
- State v. Chabot, 682 A.2d 1377 (R.I. 1996) (factors to evaluate whether waiver of counsel is voluntary, knowing, and intelligent)
- State v. Gallop, 89 A.3d 795 (R.I. 2014) (two-step test for suppression of identifications: suggestiveness then reliability)