State v. McRae
31 A.3d 785
R.I.2011Background
- McRae was charged in 2008 with domestic assault with a dangerous weapon and domestic simple assault arising from a 2007 incident with Iniabet DelValle.
- The trial proceeded in March 2010; the jury acquitted on the dangerous-weapon count but convicted McRae of domestic simple assault, a third domestic conviction.
- He was sentenced to ten years with one year to serve and nine years suspended, with probation, under DV statutes for a third domestic offense.
- Facts at trial showed a disputed doorstep confrontation: DelValle testified McRae grabbed her, held a knife at her throat, and injured her; McRae testified she pulled the key away and fell, with no assault or knife by him.
- Two police officers and DelValle testified; McRae was the sole defense witness; the case included evidence of a prior relationship and related interactions.
- On appeal, McRae challenged (a) the denial of a pass after DelValle testified about his drinking and (b) the admission of seven prior convictions for impeachment; the Rhode Island Supreme Court decided the issues without further briefing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| whether the trial court erred by not passing the case after testimony about drinking | McRae | McRae | No error; no prejudicial taint; cautionary instruction adequate |
| whether admitting seven prior convictions for impeachment was an abuse of discretion | McRae | McRae | No abuse of discretion; convictions within ten years and probative for credibility; cautionary instruction given |
Key Cases Cited
- Handy v. Geary, 105 R.I. 419 (R.I. 1969) (pretrial intoxication inquiry principle)
- State v. Amaral, 109 R.I. 379 (R.I. 1972) ( intoxication evidence admissibility guidance)
- State v. Rosario, 14 A.3d 206 (R.I. 2011) (prejudicial impact governs passing a case)
- State v. LaPlante, 962 A.2d 63 (R.I. 2009) (contextual prejudice assessment for extraneous evidence)
- State v. Gongoleski, 14 A.3d 218 (R.I. 2011) (discretion in admitting prior convictions for impeachment)
- State v. Remy, 910 A.2d 796 (R.I. 2006) (impeachment of witnesses using prior convictions standard)
- State v. Vargas, 991 A.2d 1056 (R.I. 2010) (time distance as factor in Rule 609 balancing)
- State v. Rodriguez, 731 A.2d 726 (R.I. 1999) (prior similar convictions admissible for impeachment)
- State v. Maxie, 554 A.2d 1028 (R.I. 1989) (impeachment use of prior convictions)