State v. Justin Prout, 116 A.3d 196

In 2006 Justin Prout was convicted of breaking and entering, assault with a dangerous weapon, and simple assault; he received concurrent sentences including a thirteen-year suspended term with probation on the felony-assault count.
On June 19, 2012, an altercation occurred in the ACI High Security Center E Module between Prout and correctional officer Christian Torres, leaving Officer Torres injured and treated for a concussion and other injuries.
Three correctional officers testified that Prout was handcuffed in front, struck Officer Torres (including blows to the head), and continued to assault him until multiple officers subdued Prout.
Prout testified he was handcuffed behind his back, that Officer Torres attacked him after a dispute about toilet paper, and that he was beaten by officers; photographs show Prout bleeding and his hands cuffed in front at the dispensary.
RIDOC policy documents indicated inmates should generally be handcuffed behind the back, but officers testified that front-cuffing was standard for shower retrievals and that policy deviations for practical reasons were common.
The Superior Court found Prout was the aggressor, credited the officers’ testimony over Prout’s, adjudicated a probation violation for failure to keep the peace, and ordered execution of the thirteen-year suspended sentence; the Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the hearing justice acted arbitrarily or capriciously in finding a probation violation based on credibility determinations	State: evidence and officer testimony reasonably satisfy the lower burden for probation revocation	Prout: hearing justice disregarded his testimony, injuries, and the RIDOC handcuffing policy undermining officers’ credibility	Court: Affirmed; hearing justice made rational credibility findings supported by reasonably satisfactory evidence and did not act arbitrarily
Effect of RIDOC handcuffing policy deviations on credibility and probative value	State: officers acknowledged policy but explained common-sense, practice-based deviations (e.g., front-cuffing for showers)	Prout: officers’ admitted deviation from written policy makes them incredible; policy noncompliance undermines state's case	Court: Policy deviation did not render officers incredible; deviation explained and not dispositive; bench found officers’ explanations plausible

State v. Barrientos, 88 A.3d 1130 (R.I. 2014) (probation-violation issue limited to whether defendant failed to keep the peace or remain in good behavior)
State v. Ford, 56 A.3d 463 (R.I. 2012) (lower burden of proof at probation-violation hearings; credibility determination central)
State v. Raso, 80 A.3d 33 (R.I. 2013) (great deference to hearing justice’s credibility assessments in probation-revocation proceedings)
State v. Prout, 996 A.2d 641 (R.I. 2010) (direct appeal affirming underlying convictions)