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252 A.3d 1236
R.I.
2021
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Background

  • Defendant Matthew Sheridan was indicted for first-degree sexual assault alleging oral penetration of a 15-year-old complainant (pseudonym: Jasper); defense maintained the contact was consensual.
  • The prosecution disclosed pediatrician/child-abuse expert Dr. Amy Goldberg shortly before trial and the defense moved to exclude her testimony as late, improper expert evidence, and bolstering.
  • Dr. Goldberg was qualified and testified (without cross-examination) that, to a reasonable degree of medical certainty, an adolescent male can become erect and ejaculate in response to unwanted tactile stimulation; she had not examined Jasper.
  • The trial justice allowed the testimony but limited its foundation to Dr. Goldberg’s training and experience (excluding reliance on medical literature) and delayed her testimony to give defense preparation time; defense did not request further continuance and did not cross-examine.
  • During voir dire the prosecutor twice (after an initial admonition) referred to Jasper as the “victim”; defense objected initially but did not move for mistrial or ask for a curative instruction and accepted the jury.
  • The jury convicted Sheridan; on appeal he argued the expert disclosure was untimely and prejudicial, the expert invaded the jury’s province, and the prosecutor’s use of “victim” prejudiced the jury. The Supreme Court affirmed.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Timeliness of expert disclosure / discovery remedy State: late disclosure cured by trial court’s remedy (limiting basis and delaying testimony) Sheridan: disclosure was tardy and prejudicial; remedy insufficient (no continuance) Court: no abuse of discretion; remedy was fair, defense acquiesced and received relief (limitations and delay)
Admissibility / jury‑province of expert testimony State: expert testimony on physiological possibility aids jurors beyond lay knowledge Sheridan: jurors could assess erection/ejaculation reaction without expert; testimony invaded jury’s province Court: expert testimony was within Rule 702 scope and helpful; not beyond jury’s province; admission proper
References to complainant as “victim” during voir dire State: initial use inadvertent; trial court admonished counsel to avoid term Sheridan: prosecutor’s repeated use created juror bias that warranted relief Court: issue waived (no contemporaneous objection/mistrial request and jury accepted); no reversal

Key Cases Cited

  • State v. Rainey, 175 A.3d 1169 (R.I. 2018) (discussing remedies for late discovery and exclusion as drastic)
  • State v. Coelho, 454 A.2d 241 (R.I. 1982) (trial judge’s discretion to fashion equitable discovery remedies)
  • State v. Adams, 161 A.3d 1182 (R.I. 2017) (timely discovery requirement and appellate deference)
  • State v. Roscoe, 198 A.3d 1232 (R.I. 2019) (expert testimony helpfulness threshold)
  • State v. Wheeler, 496 A.2d 1382 (R.I. 1985) (weight jurors give expert testimony and helpfulness principle)
  • State v. Marte, 92 A.3d 148 (R.I. 2014) (appellate review of discovery rulings)
  • State v. Simpson, 595 A.2d 803 (R.I. 1991) (disclosure timing and prejudice analysis)
  • Barenbaum v. Richardson, 328 A.2d 731 (R.I. 1974) (no necessity for expert where jury can draw correct conclusions)
Read the full case

Case Details

Case Name: State v. Matthew Sheridan
Court Name: Supreme Court of Rhode Island
Date Published: Jun 24, 2021
Citations: 252 A.3d 1236; 18-234
Docket Number: 18-234
Court Abbreviation: R.I.
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    State v. Matthew Sheridan, 252 A.3d 1236