State v. Miguel Davis, 131 A.3d 679

March 20, 2009, Dominique Gay is murdered in Providence; Miguel Davis is charged over three offenses.
Davis had a prior contentious relationship with Gay’s former partner Crystal Dutra; tensions arose from alleged romantic entanglements.
Andujar is the only eyewitness verdict-witness who testifies at trial; Robinson expected to testify but invokes Fifth Amendment.
Forensic evidence shows two 9mm cartridge cases and bullets of .38 caliber class; murder weapon not recovered.
State proves Davis’s access to firearms through multiple witnesses; gun-ownership testimony is used to infer motive and opportunity.
Trial results: conviction on murder, felony firearm, and gun-possessing charges; two life sentences plus a 10-year term, all concurrent where noted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court erred by not giving a limiting instruction about opening statements	Davis argues prejudicial pretrial opening tainted jury	Court should have curbed prejudicial opening with limiting instruction	No reversible error; no obligation to give limiting instruction; cure available via admonitions
Whether eyewitness identification instructions were required	Andujar’s identification was unreliable; Biggers factors should guide jury	Existing Rhode Island law allows general instructions; no mandatory Biggers-type instruction	No reversible error; trial court complied with acceptable identification guidance
Whether admission of 404(b) gun-evidence was improper	Evidence showed Davis’s access to firearms; relevant to motive/access	Evidence is prejudicial and not properly linked to charged crime	Waived; trial court rulings not unequivocally definitive; issue not reviewed on merits
Whether in-life family portrait was admissible to inflame sympathy	Photograph helps identify victim and context of offense	Photo constitutes improper sympathy-persuasion	Waived; in limine ruling not unequivocally final; issue not reviewed on merits
Whether denial of motion for a new trial was proper	Key witnesses were credible and supported verdict	New trial warranted due to alleged unreliability of main witnesses	No error; trial court properly weighed credibility and evidence; verdict affirmed

State v. Andrade, 544 A.2d 1140 (R.I. 1988) (identification instructions not mandatory; rely on general ID guidance)
State v. Payette, 557 A.2d 72 (R.I. 1989) (identification instruction not mandatory; general instructions sufficient)
State v. Gomes, 604 A.2d 1249 (R.I. 1992) (eyewitness identification guidance not mandatory; balancing probative value vs. prejudice)
State v. Werner I, 831 A.2d 183 (R.I. 2003) (eyewitness cautionary instruction discussed; limits of comment on evidence)
State v. Werner II, 851 A.2d 1093 (R.I. 2004) (court approved overarching eyewitness guidance without mandatory Biggers-type instruction)
State v. Austin, 114 A.3d 87 (R.I. 2015) (instruction on eyewitness factors permissible; tailored to case)
State v. Rios, 996 A.2d 639 (R.I. 2010) (Rule 404(b)–205-like analysis; access to guns admissible with 403 balancing)