State v. Kunwar Chadha, 19-438

Background

Defendant Kunwar Chadha was indicted for multiple counts of child molestation based on four alleged incidents occurring when the victim (pseudonym "Matthew") was a minor. Trial covered events in 2011–2012.
At trial Matthew testified to four incidents of sexual contact and penetration; he later disclosed the abuse to a counselor, who reported it to police.
Defense sought to cross-examine Matthew about (a) an earlier "peanut butter" prank (allegedly putting peanut butter in a bully’s drink) and (b) prior allegations Matthew made against a third party (the "Cagno allegation"). The trial justice excluded both lines of inquiry.
The jury acquitted Count One (first-degree penetration), convicted on Count Three (second-degree molestation), was hung on Count Four, and convicted on one of two separate questions submitted under Count Five.
The trial justice denied defendant’s motion for a new trial and imposed consecutive sentences. Defendant appealed asserting (1) improper restriction of confrontation/cross-examination and (2) error in denying a new trial (including alleged inconsistent verdicts). The Supreme Court affirmed.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Chadha)	Held
Whether questioning about the "peanut butter" incident should have been allowed under R.I. R. Evid. 608(b) to attack credibility	Exclusion was proper because the incident was not probative of truthfulness under Rule 608(b) and could be excluded under Rule 403	The incident showed Matthew could be a purposeful wrongdoer and undercut his self-portrayal as only a victim; it was probative of credibility	Exclusion was within the trial justice’s discretion; 608(b) did not apply and the evidence was properly excluded (403)
Whether cross-examination and calling a witness about the Cagno allegation (prior sexual accusation against another) should have been permitted	Exclusion was proper under Rule 403: the prior allegation was materially different in nature and age and would invite collateral issues	The Cagno allegation bore on Matthew’s propensity to make false accusations and on his knowledge of sexual conduct; thus it was probative of credibility under 608(b)	Trial justice did not abuse discretion; prior allegation was fundamentally different and exclusion was appropriate under Rule 403
Whether the trial justice erred in denying a new trial (alleged overlooked evidence and legally inconsistent verdicts)	Trial justice properly weighed credibility, reviewed the record, and applied the DeOliveira standard; verdicts were supported by evidence	Trial justice overlooked material evidence and the Count Five results (guilty on touching but hung on forced-touching) produced legally inconsistent verdicts violating due process	Denial of new trial affirmed: trial justice conducted required analysis and did not overlook material evidence; Count Five verdicts are not legally inconsistent because either act would support conviction

Key Cases Cited

Allen v. United States, 164 U.S. 492 (Allen charge authorizes instruction to encourage further jury deliberations)
State v. Manning, 973 A.2d 524 (Sixth Amendment confrontation and cross-examination rights subject to reasonable trial-court limits)
State v. Dorsey, 783 A.2d 947 (prior accusations that are fundamentally different may be excluded)
State v. Oliveira, 576 A.2d 111 (prior allegations of sexual assault may be admissible to challenge credibility)
State v. Anthony, 422 A.2d 921 (cross-examiner must be given reasonable latitude but limits are allowed for relevance and prejudice)
State v. DeOliveira, 972 A.2d 653 (standard and required steps for a trial justice ruling on a motion for new trial)
State v. Arroyo, 844 A.2d 163 (definition and analysis for legally inconsistent verdicts)
State v. Rivera, 987 A.2d 887 (appellate review of trial-court limitations on cross-examination is for clear abuse of discretion)