State v. Keith J. Pittman, 15-370

On January 17, 2013, Ryan Laughlin was robbed on Wickenden Street while carrying a messenger bag; his roommate Kyle Nichols‑Schmolze chased the two suspects and recovered the bag after one man stopped in a driveway under a light.
Nichols‑Schmolze saw the man clearly for a brief interval (estimated 5–15 seconds) and later provided a license‑plate number shouted at the scene; Laughlin relayed the plate to 911.
The plate traced to a silver Nissan registered to Dena Magiera; police found that defendant Keith J. Pittman had access to and used that car.
Nichols‑Schmolze identified Pittman in a photo array within a day or two and made an unequivocal in‑court identification at trial; Laughlin could not identify anyone from the array.
A jury convicted Pittman of second‑degree robbery; the trial justice denied his Rule 33 motion for a new trial and sentenced him to 20 years (16 to serve, 4 suspended). Pittman appealed; the Supreme Court affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Pittman)	Held
Whether the trial justice erred in denying the motion for a new trial under Rule 33 (verdict against weight of evidence).	Evidence (witness credibility, plate tracing to Magiera, prompt photo ID, and access to car) supports the jury verdict; no material evidence was overlooked.	Trial justice overlooked and misconceived material evidence; verdict against the fair preponderance because ID was unreliable and observation was brief/dark.	The trial justice did not commit clear error or overlook material evidence; denial of new trial affirmed.
Whether the photographic and in‑court identifications were sufficiently reliable to support conviction.	Nichols‑Schmolze’s quick, confident identification and corroborating physical evidence (license plate → car access) made the ID reliable.	The ID was uncertain (witness admitted not 100% certain) and based on a short, nighttime view—insufficient to support conviction beyond a reasonable doubt.	Court found the photo and in‑court IDs reliable when viewed with corroborating evidence; the ID supported the conviction.

State v. Williams, 137 A.3d 682 (R.I. 2016) (standard for appellate review of trial‑court denial of new trial)
State v. Mendez, 116 A.3d 228 (R.I. 2015) (trial justice acting as thirteenth juror when reviewing weight‑of‑evidence motions)
State v. Texieira, 944 A.2d 132 (R.I. 2008) (deference to trial justice who observed witnesses)
State v. Silva, 84 A.3d 411 (R.I. 2014) (steps trial justice must take when ruling on weight‑of‑evidence/new‑trial motion)
State v. Barrios, 88 A.3d 1123 (R.I. 2014) (trial justice’s role in credibility and weight assessments)