State v. Michael Stokes, 200 A.3d 144

On October 17, 2015, a shooting at El Tiburon bar in Providence injured three patrons; defendant Michael Stokes was later arrested in North Carolina and charged with multiple counts including assault with a dangerous weapon and discharging a firearm while committing a crime of violence.
Three victims testified; only Tameisha Haynes positively identified Stokes at trial as the shooter. Alize Huntley (wounded) initially identified Stokes in a hospital statement but recanted or claimed impaired memory at trial.
Defense counsel filed discovery motions seeking information about promises, inducements, and witness-protection-related material; the State’s midtrial answer disclosed that Haynes and Huntley had been placed in a witness protection program.
At trial Huntley was declared hostile; the court admitted her October 21, 2015 police statement and audio recording as prior inconsistent statements under Rule 801(d)(1)(A) and allowed the jury to hear the recording.
The jury convicted Stokes on all counts; the trial justice denied a motion for a new trial, crediting Haynes’s in-court ID and Huntley’s recorded statement, and citing other evidence (video color distortion, defendant’s flight to North Carolina).

Issue	Plaintiff's Argument (State)	Defendant's Argument (Stokes)	Held
Timeliness of disclosure under Rule 16 (witness-protection info)	Disclosure not prejudicial; State had complied with discovery and later provided responsive information	Late disclosure of witness-protection participation prejudiced defense and denied opportunity to present best defense	Waived by Stokes for failure to object at trial; not preserved for appeal
Admissibility of Huntley’s prior statement (Rule 801(d)(1)(A))	Prior inconsistent statement admissible because Huntley testified and was subject to cross-examination about it	Statement inadmissible because Huntley claimed drug-affected memory, making cross-examination ineffective	Admissible; trial justice did not abuse discretion in admitting transcript and audio for impeachment and as substantive evidence
Denial of motion for a new trial	Verdict supported by credible eyewitness ID (Haynes), Huntley’s recorded statement, investigative testimony, and defendant’s flight	Trial justice erred in crediting Huntley and Haynes given inconsistencies and video color discrepancy	Denial affirmed; trial justice properly acted as thirteenth juror and found no basis to overturn the jury verdict

State v. Perry, 182 A.3d 558 (R.I. 2018) (preservation/raise-or-waive rule for appellate review)
State ex rel. Town of Tiverton v. Pelletier, 174 A.3d 713 (R.I. 2017) (issues not raised at trial are generally waived)
State v. Marte, 92 A.3d 148 (R.I. 2014) (factors for evaluating alleged discovery violations under Rule 16)
State v. Jaiman, 850 A.2d 984 (R.I. 2004) (prior inconsistent statements admissible where witness testifies and is cross-examined)
State v. McManus, 990 A.2d 1229 (R.I. 2010) (admission of prior inconsistent statements despite claimed memory failure)
State v. Matthews, 88 A.3d 375 (R.I. 2014) (audio recordings of prior statements may be admitted under Rule 801(d)(1)(A) when witness is cross-examined)
State v. Cerda, 957 A.2d 382 (R.I. 2008) (standards for trial justice review of motions for new trial)