State v. Payette
2012 R.I. LEXIS 27
| R.I. | 2012Background
- Payette murdered Ronald Dufour over a $510 debt and attempted to conceal the killing.
- Payette invited Dufour to his West Warwick apartment, got him drunk, and stabbed him after a scuffle outdoors.
- He dragged Dufour’s body into a wooded ravine and disposed of bloody clothing in a dumpster.
- Payette and a housemate discussed further concealing evidence but ultimately did not take additional steps.
- Payette was indicted for murder in 2008 and convicted of first-degree murder in 2009, receiving a life sentence.
- On appeal, Payette challenged jury instructions on inferred malice and the denial of his motion for a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Malice inference from size/strength disparity | Payette argues the instruction was improper and prejudicial. | Payette contends the disparity is insufficient here and may confuse jurors. | Instruction proper; supported by evidence and law. |
| Denial of motion for a new trial | Payette asserts the court overlooked material intoxication evidence negating intent. | Payette maintains diminished capacity warranted a new trial. | No clear error; denial affirmed. |
Key Cases Cited
- State v. Cipriano, 21 A.3d 408 (R.I. 2011) (standard de novo review of jury instructions)
- State v. Ros, 973 A.2d 1148 (R.I. 2009) (integrated review of instructions in context)
- State v. Linde, 876 A.2d 1115 (R.I. 2005) (instructions must cover the law; not single sentences in isolation)
- State v. Ibrahim, 862 A.2d 787 (R.I. 2004) (examination of jury instructions in context)
- State v. McGranahan, 415 A.2d 1298 (R.I. 1980) (malice can be inferred from disparity in size/strength)
- State v. Oliveira, 774 A.2d 893 (R.I. 2001) (affirmed inference of malice from disproportionate size/strength)
- Commonwealth v. Moore, 488 Pa. 361, 412 A.2d 549 (Pa. 1980) (size/strength disparity relevant to malice inference)
- Commonwealth v. Buzard, 76 A.2d 394 (Pa. 1950) (eight-inch/forty-five-pound disparity considered for malice inference)
- Sadler v. Texas, 364 S.W.2d 234 (Tex. Crim. App. 1963) (size/strength disparity among adults supports intent evidence)
- Beavers v. Commonwealth, 245 Va. 268, 427 S.E.2d 411 (Va. 1993) (disparity in size/strength/age considered for intent)