State v. Lawrence Clay
79 A.3d 832
| R.I. | 2013Background
- On Oct. 29, 2009, a 14‑year‑old girl ("Jones") left her grandparents’ Middletown home to meet a boyfriend and got into Lawrence Clay’s green Nissan after he threatened to shoot her if she didn’t comply.
- Clay covered Jones with a tarpaulin and drove her across city lines; during the trip Jones was concealed, struck when she attempted to seek help, and later alleges he sexually assaulted her at a football field.
- Jones escaped in New Bedford; witnesses, surveillance (Dunkin’ Donuts), and items seized from Clay’s vehicle (including Jones’s pajama bottoms and funeral cards) corroborated parts of her account.
- Clay was arrested after a high‑speed chase; statements to police included explanations minimizing wrongdoing.
- A jury convicted Clay of kidnapping of a minor and reckless driving; he was sentenced to 60 years (30 to serve, 30 suspended), and his suspended probationary sentences were vacated after a probation‑violation adjudication.
- On appeal Clay argued (1) the trial court erred by admitting testimony about the alleged sexual assault in the kidnapping trial and (2) the trial justice abused discretion in denying his motion for a new trial.
Issues
| Issue | State's Argument | Clay's Argument | Held |
|---|---|---|---|
| Admissibility of alleged sexual‑assault testimony under Rule 404(b) | Assault evidence was inextricably woven into the kidnapping, probative of motive/intent, and necessary for a coherent narrative | Evidence was propensity evidence unrelated to kidnapping, unduly prejudicial and should be excluded | Evidence admissible: assault occurred during the same continuous event and was properly admitted under Rule 404(b) and 403 with limiting instructions |
| Prejudice and Rule 403 balancing for sexual‑assault testimony | Probative value (motive/intent; coherent story) outweighed prejudice; court gave limiting instructions | Graphic nature and risk jury would conflate charges made the evidence unfairly prejudicial | No abuse of discretion: trial justice considered prejudice, gave limiting instructions, and did not err |
| Motion for new trial — weight and credibility of evidence | Jury verdict supported by corroborating evidence and jury credibility findings | Witness inconsistencies, lies, and changing statements required a new trial because testimony was unreliable | Denial affirmed: trial justice acted as 13th juror, reviewed credibility and weight, did not overlook or misconceive material evidence |
| Sentencing/probation‑violation adjudication (consolidated review) | State proceeded with probation‑violation hearing; trial justice vacated suspended sentences and imposed concurrent terms | Clay sought review of probation adjudications on appeal (consolidated) | Supreme Court affirmed trial court’s rulings and sentences; |
Key Cases Cited
- State v. Pona, 948 A.2d 941 (R.I. 2008) (inadmissible 404(b) evidence can unfairly highlight propensity when not closely related to charged offense)
- State v. Martinez, 59 A.3d 73 (R.I. 2013) (Rule 404(b) allows other‑act evidence for motive, intent, plan; not automatically excluded if it suggests past wrongdoing)
- State v. Rios, 996 A.2d 635 (R.I. 2010) (admissibility of evidence reviewed for abuse of discretion)
- State v. Mlyniec, 15 A.3d 983 (R.I. 2011) (Rule 403 balancing is required when admitting otherwise relevant Rule 404(b) evidence)
- State v. LaPierre, 57 A.3d 305 (R.I. 2012) (trial justice acting as thirteenth juror must state grounds when denying new‑trial motion; appellate review is deferential)