State v. Luis Barrios
2014 R.I. LEXIS 43
| R.I. | 2014Background
- Complainant ("Anna") was walking home after drinking at a bar on July 22–23, 2010, when a car pulled up and a man walked alongside her, groped her over clothes, and threw a Taco Bell cup as she fled to a house on George Street.
- Police responded to a 911 call, took Anna to nearby addresses, and she identified defendant Luis Barrios from a photograph and later from a person brought closer to the police car at defendant’s Morgan Avenue residence.
- Defendant testified he drove Fernando Justiniano home that night, denied the assault, and claimed Anna misidentified him (asserting Justiniano resembled him and had been in the car).
- Police recovered the cup but did not fingerprint it; Justiniano did not testify (defendant said he left the country).
- A jury convicted Barrios of two counts of second-degree sexual assault and acquitted him of simple assault; the trial justice denied Barrios’s motion for a new trial and sentenced him to concurrent suspended three-year terms with probation.
- On appeal Barrios challenged only the denial of his motion for a new trial, arguing misidentification and investigative flaws created reasonable doubt.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Barrios) | Held |
|---|---|---|---|
| Sufficiency of identification / reliability of witness ID | Anna’s identification was unequivocal, corroborated by police and consistent with her description; jury verdict supported by evidence | Anna was intoxicated, lighting and distance cast doubt, and she may have mistaken Barrios for Justiniano | Trial justice independently reviewed credibility, found Anna credible and ID reliable; denied new trial; Supreme Court affirmed |
| Investigation / missed forensic steps (cup, lineup) | Failure to fingerprint cup or use side-by-side ID does not render verdict unreliable where ID testimony and police procedures were credible | Police investigation was flawed (no fingerprints, no side-by-side ID), undermining confidence in ID and guilt | Trial justice credited detectives and officers, found investigative omissions insufficient to undermine verdict; Supreme Court affirmed |
Key Cases Cited
- State v. Rosario, 35 A.3d 938 (R.I. 2012) (trial justice acts as thirteenth juror on new-trial motion)
- State v. Silva, 84 A.3d 411 (R.I. 2014) (three-step framework for independent review of new-trial motion)
- State v. DiCarlo, 987 A.2d 867 (R.I. 2010) (trial justice should provide brief reasons sufficient for appellate review)
- State v. Paola, 59 A.3d 99 (R.I. 2013) (appellate deference to trial justice unless he overlooked or misconceived material evidence)
- State v. Guerra, 12 A.3d 759 (R.I. 2011) (if reasonable minds could differ, motion for new trial should be denied)