State v. Mark Ceppi, 91 A.3d 320

Defendant Mark Ceppi was charged by information with domestic felony assault causing serious bodily injury and domestic simple assault based on incidents involving Heather King.
Ceppi moved to dismiss the information under Rule 9.1 and § 12-12-1.7, arguing the information failed to establish probable cause.
The Superior Court denied the motion after a hearing; trial proceeded in Newport County Superior Court with a bench trial.
King testified to two incidents: a March 2009 simple assault and a May 2009 felony assault allegedly causing a subdural hematoma.
The State introduced King’s medical records; defense did not object to their admission; the court found King credible and convictable on both counts.
Ceppi was convicted on Count One (felony assault) and Count Two (simple assault) on the basis of the trial record and was sentenced to prison terms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable-cause sufficiency in information	Ceppi argues the package lacked probable cause for both counts.	Ceppi contends Rule 9.1 requires dismissal for insufficient information.	Harmless error; convictions cure probable-cause defects.
hearsay and bolstering in Detective Hayes' testimony	Hayes' testimony included statements from King and physician about injuries.	These statements were hearsay and impermissibly bolstering the witness credibility.	Harmless error; cumulative evidence and medical records supported the same facts.
Cross-examination about past violence involving Ceppi's former wife	Questioning suggested prior violent conduct by Ceppi.	Rule 404(b) violation; evidence improperly linked to character.	Harmless error; no 404(b) documents admitted and defense denied; no prejudice.
Lay opinion on intoxication of the complainant	Defense sought to elicit King’s intoxication observations as lay opinion.	Court should allow lay observations of intoxication based on concrete details.	Permitted as lay observations with concrete details; no error.

State v. Martini, 860 A.2d 689 (R.I. 2004) (probable-cause standard for information review; four-corners approach)
State v. Fritz, 801 A.2d 679 (R.I. 2002) (probable-cause review; four-corners analysis)
State v. Jenison, 442 A.2d 866 (R.I. 1982) (probable cause and standard of review)
State v. Baillargeron, 58 A.3d 194 (R.I. 2013) (probable cause assessment; benefit of reasonable inferences)
State v. Simpson, 658 A.2d 522 (R.I. 1995) (grand-jury-indictment dismissal is extraordinary; conviction can cure defects)
United States v. Mechanik, 475 U.S. 66 (U.S. 1986) (harmless-error doctrine for grand-jury defects after conviction)
State v. Aponte, 649 A.2d 219 (R.I. 1994) (limits of applying grand-jury standards to information dismissals)
State v. Medeiros, 996 A.2d 115 (R.I. 2010) (harmlessness of evidentiary error in jury-waived trials)
State v. Clements, 83 A.3d 553 (R.I. 2014) (harmless error review for Rule 404(b) violations)
State v. Bailey, 677 A.2d 407 (R.I. 1996) (harmless error principle; Rule 404(b) considerations)