State v. Matthew Jones, 242 A.3d 47

Jones was charged with two counts of felony assault (golf-club attacks on two neighbors on March 4, 2013).
First jury trial (2017) ended in a mistrial; during that proceeding certain rulings were made about prior convictions.
Between trials Jones acquired a new felony conviction (controlled substances distribution), expanding his criminal record.
At the second trial (2018) Jones testified and claimed self-defense (attacked by a neighbor’s dog and others); the State sought to impeach his credibility with prior convictions including a 1996 felony assault.
The second trial justice, citing Rule 609 and the expanded record, admitted prior convictions from 1995 onward (with some exclusions and an expurgated reference to the 1996 conviction as simply a “felony assault”) and gave a limiting instruction.
A jury convicted Jones on both counts; he was sentenced to concurrent terms. Jones appealed, arguing the 1996 conviction should have been excluded under the law of the case and as unduly prejudicial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial justice abused discretion by admitting Jones’s 1996 felony-assault conviction for impeachment and whether the law-of-the-case doctrine barred reconsideration	The State: prior convictions are admissible under Rule 609 to impeach credibility, and the new conviction between trials makes the expanded record relevant	Jones: first trial justice excluded the 1996 conviction; law of the case should bar reconsideration and the conviction is remote and unduly prejudicial, suggesting propensity for violence	The court held the law of the case did not bar reconsideration because of an expanded record; admission under Rule 609 was within the trial justice’s broad discretion, especially given Jones’s lengthy criminal history and limiting measures taken

State v. Whitfield, 93 A.3d 1011 (R.I. 2014) (Rule 609 standard; trial court has broad discretion on admissibility of prior convictions for impeachment)
State v. Tetreault, 31 A.3d 777 (R.I. 2011) (factors for impeachment with prior convictions)
Lynch v. Spirit Rent‑A‑Car, Inc., 965 A.2d 417 (R.I. 2009) (law‑of‑the‑case doctrine may be disregarded when record is expanded)
Chavers v. Fleet Bank (RI), N.A., 844 A.2d 666 (R.I. 2004) (law‑of‑the‑case described as flexible; may yield to expanded record)
State v. McRae, 31 A.3d 785 (R.I. 2011) (Rule 609 requires balancing probative value against prejudicial effect)
State v. Remy, 910 A.2d 793 (R.I. 2006) (Rhode Island Rule 609 is broader than federal counterpart; prior crimes inform jury’s assessment of respect for law and truthfulness)
State v. McWilliams, 47 A.3d 251 (R.I. 2012) (upholding admission of a long‑ago conviction when defendant’s record showed many convictions over time)
State v. Mattatall, 603 A.2d 1098 (R.I. 1992) (similar holding that remoteness does not automatically bar impeachment by similar prior offense)