State v. Oscar Muralles
154 A.3d 925
| R.I. | 2017Background
- Defendant Oscar Muralles was indicted on multiple counts of first- and second-degree child molestation based on allegations by his former stepson ("Rick") concerning incidents from ~2002–2008; Rick was ~15 at trial.
- Rick testified in detail about several sexual incidents; his younger half-brother, Oliver, testified he witnessed at least one incident (demonstrated at trial).
- Medical exam by child-abuse pediatricians was normal; experts explained normal exams do not rule out abuse.
- At trial the court granted Rule 29 acquittals on three counts; a jury convicted Muralles on four remaining counts. The trial justice denied Muralles’ motion for a new trial.
- Sentences: concurrent lengthy terms (first-degree counts: 50 years, 35 to serve; second-degree counts: 25 years, 10 to serve, with portions suspended). Muralles appealed only the denial of the new-trial motion, arguing the trial justice overlooked/misconceived evidence and erred weighing credibility.
Issues
| Issue | State's Argument | Muralles' Argument | Held |
|---|---|---|---|
| Whether the trial justice erred in denying the motion for a new trial by overlooking or misconceiving material evidence and credibility issues | Trial justice properly performed the three-step inquiry, independently assessed credibility, found corroboration (Oliver), and would have reached same verdict | Trial justice ignored testimonial inconsistencies, memory lapses, alleged implausibilities, and improperly attributed flaws to questioning/embarrassment | Denial affirmed: trial justice applied the correct standards, made reasoned credibility findings, and did not overlook or misconceive material evidence |
| Whether the jury verdict failed to do substantial justice given alleged inconsistencies between witnesses | State: inconsistencies were minor; corroboration and steadiness of accusations support verdict | Muralles: inconsistencies and alleged logistical problems undermine verdict’s reliability | Court: inconsistencies did not render testimony incredible; reasonable minds could differ and trial justice would have reached the same result — motion properly denied |
Key Cases Cited
- Silva v. State, 84 A.3d 411 (R.I. 2014) (describes three-step inquiry for new-trial motions)
- Robat v. State, 49 A.3d 58 (R.I. 2012) (explains fourth-step review when trial justice disagrees with jury and the substantial-justice inquiry)
- DiCarlo v. State, 987 A.2d 867 (R.I. 2010) (trial justice must not overlook or misconceive material evidence; record should reflect reasoning)
- Mattatall v. State, 603 A.2d 1098 (R.I. 1992) (disbelief of defendant’s testimony can support conviction; defendant who testifies risks being disbelieved)
- Paola v. State, 59 A.3d 99 (R.I. 2013) (deference to trial justice who observed witnesses and judged credibility)