47 A.3d 251
R.I.2012Background
- Raymond McWilliams was convicted on one count of first-degree robbery and one count of assault with a dangerous weapon in a dwelling.
- The trial court sentenced him to life in prison for robbery, plus 11.5 years for probation violation, with the two sentences running consecutively; the assault sentence was concurrent to robbery but consecutive to the murder sentence.
- Because McWilliams qualified as a habitual offender under G.L.1956 § 12-19-21, the court added an additional 10 years consecutive to prior sentences.
- McWilliams challenged a supplemental jury instruction on intent to permanently deprive, alleged bias requiring recusal, admission of prior second-degree murder conviction, denial of acquittal, and denial of a new trial.
- The Rhode Island Supreme Court affirmed, concluding no reversible error on any issue.
- Key evidence included Erica Boutelle’s identification of McWilliams, his probation-violation and bail hearing, and his prior criminal record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether supplemental jury instruction on deprival was correct | McWilliams | McWilliams | Instruction proper; no error |
| Whether the trial judge should have recused for bias | McWilliams | McWilliams | No recusal required; no bias shown |
| Whether admission of prior second-degree murder conviction was improper | State | McWilliams | Proper under Rule 609; no abuse of discretion |
| Whether denial of acquittal was correct | State | McWilliams | Correct; sufficient evidence supported verdict |
| Whether denial of a new trial was correct | State | McWilliams | Correct; no basis to grant new trial |
Key Cases Cited
- State v. Cipriano, 21 A.3d 408 (R.I. 2011) (standard of review for jury instructions)
- State v. Ros, 973 A.2d 1148 (R.I. 2009) (jury instruction review framework)
- State v. Linde, 876 A.2d 1115 (R.I. 2005) (comprehensive review of jury charges)
- State v. Howard, 23 A.3d 1133 (R.I. 2011) (recusal/prejudice considerations and demeanor of judges)
- State v. Nordstrom, 122 R.I. 412 (1979) (bias concerns and comments during trial)
- State v. Mattatall, 603 A.2d 1098 (R.I. 1992) (Rule 609 balancing and credibility impeachment relevance)
- State v. Coleman, 909 A.2d 929 (R.I. 2006) (remote convictions and impeachment value)
- State v. Silvia, 898 A.2d 707 (R.I. 2006) (Rule 609Application and discretion)