State v. Nayquan Gadson, 87 A.3d 1044

Defendant Nayquan Gadson was convicted of second-degree robbery in Providence County after a five-day trial in 2010.
Codefendant Michael Stokes faced related charges; Stokes's Count Seven was severed, while Count Six remained joined with Gadson's case.
Judd, a cooperator with a favorable Memorandum of Agreement, testified about the robbery and identified Gadson and Stokes.
Judd testified that Gadson retrieved a handgun and participated in the robbery; Moran’s dog chased Judd during the incident.
The jury found Gadson guilty of second-degree robbery and not guilty of larceny from the person, with a misheard and later clarified verdict in the courtroom.
Gadson challenged (i) the sufficiency of the robbery verdict after the lesser-included offense result, (ii) the denial of a severance as to Count Six, and (iii) an in limine ruling about firearm connection evidence; the Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the not-guilty on the lesser offense required dismissal	Gadson argues acquittal on larceny from the person requires dismissal of robbery.	Gadson contends the jury’s not guilty on the lesser included charge invalidates the greater charge.	Issue waived; no error preserved.
Joinder and severance of Count Six	Stokes’s firearm charge joined with Gadson’s counts prejudices Gadson.	Severance would better ensure a fair trial.	No abuse of discretion; joinder allowed; no substantial prejudice.
In limine ruling on connection between Gadson and Judd’s firearm	State should be able to introduce connection evidence between Gadson and the firearm.	Evidence of any Gadson-firearm connection should be precluded.	Not preserved for review; defense did not renew objection at trial.

Pinkerton v. United States, 328 U.S. 639 (S. Ct. 1946) (aiding and abetting or coconspirator liability principles)
State v. DeSanto, 603 A.2d 744 (R.I. 1992) (conspiracy liability context; need two or more in conspiracy)
State v. Pereira, 973 A.2d 19 (R.I. 2009) (Rule 14 severance considerations; prejudice standard)
State v. Ashness, 461 A.2d 659 (R.I. 1983) (abuse of discretion standard for severance; prejudice showings)
Zafiro v. United States, 506 U.S. 534 (S. Ct. 1993) (joinder severance due process standard)
State v. Cassey, 543 A.2d 670 (R.I. 1988) (joinder and severance rationale; clarity of evidence)
State v. Day, 898 A.2d 698 (R.I. 2006) (prejudice and severance factual balancing)
State v. Goulet, 21 A.3d 302 (R.I. 2011) (joinder/severance in multi-defendant trials)
State v. Vanasse, 593 A.2d 58 (R.I. 1991) (prejudice and severance analysis)
State v. Diefenderfer, 970 A.2d 12 (R.I. 2009) (raise-or-waive rule and preservation principles)