State v. Karngar
2011 R.I. LEXIS 124
| R.I. | 2011Background
- Karngar was convicted of breaking and entering McCarthy's apartment after three trials.
- At trial, McCarthy testified she did not invite Karngar; Karngar claimed he had a key and entered to announce presence.
- Kamara corroborated McCarthy's account; Karngar disputed damage to the door and ownership of a key.
- The trial court denied a new-trial motion challenging credibility and weight of the evidence; a prior mistrial occurred on the B&E count.
- On appeal, Karngar argued lack of credibility and insufficient evidence warrant a new trial, or that the verdict was against the weight of the evidence.
- Rhode Island Supreme Court held that the new-trial motion challenged weight, not sufficiency, and affirmed the judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the new-trial motion properly challenged sufficiency of the evidence | State contends no legal-sufficiency challenge was made | Karngar contends weight-based challenge could affect verdict | Issue not properly before Court; weight challenge only addressed |
| Whether the trial court abused its discretion by denying a weight-based new-trial motion | Evidence supported verdict; credibility issues justify guilt | Credibility flaws and conflicting testimony warrant new trial | No abuse; reasonable minds could disagree about credibility; verdict not against weight |
Key Cases Cited
- State v. Clark, 974 A.2d 558 (R.I.2009) (distinguishes sufficiency vs. weight challenges on new-trial motions)
- State v. Perkins, 460 A.2d 1245 (R.I.1983) (weight-of-evidence vs sufficiency standard)
- State v. Abdullah, 967 A.2d 469 (R.I.2009) (standard for appellate review of trial-court rulings)
- State v. Nunes, 788 A.2d 460 (R.I.2002) (double-jeopardy and weight-of-evidence considerations)
- Mattatall v. State, 603 A.2d 1098 (R.I.1992) (disbelief of defendant's testimony may sustain guilt if other evidence exists)
- In re Miguel A., 990 A.2d 1216 (R.I.2010) (raise-or-waive rule and trial-issues not preserved at trial)
- State v. Horton, 871 A.2d 959 (R.I.2005) (weighing credibility and evidence against jurycharge)
- State v. Colbert, 549 A.2d 1021 (R.I.1988) (sufficiency review on appeal from denial of new-trial motion)
- State v. Storey, 8 A.3d 454 (R.I.2010) (raise-or-waive rule for new-trial issues)