State v. Pineda, 13 A.3d 623

Maria J. Pineda was convicted of felony assault with a dangerous weapon and disorderly conduct at a joint trial with her brother Jose.
The September 2003 incident occurred at the Rodrigues apartment in Pawtucket after disputes over a missing tape, with alcohol involved and both sides alleging Fights.
Pineda testified she arrived to assist her intoxicated brother, was attacked by Rodrigues, and took a construction tool/hammer from the scene to her car.
Rodrigues testified that Pineda struck her with a hammer during a fight; police later found a two-headed hammer in Pineda’s vehicle.
The two defendants shared a private attorney who sought a stipulation waiving potential conflicts of interest from joint representation and proceeded to trial.
Post-trial, Pineda moved for acquittal and sought a self-defense instruction; the trial justice denied both motions, and sentenced Pineda to concurrent terms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court should have given a self-defense instruction	Pineda asserts a self-defense theory merited an instruction.	State contends no evidence supports self-defense for the charged hammer assault.	No self-defense instruction required; no evidence of self-defense with the charged weapon.
Whether Pineda was denied right to separate counsel due to joint representation	Joint representation concealed actual conflicts and violated Sixth Amendment rights.	No actual conflict shown; supervisory rule rejected; waiver was voluntary.	No actual conflict proven; supervisory rule not adopted.
Whether the evidence was legally sufficient to sustain the conviction/New-trial ruling	Evidence did not prove hammer assault beyond a reasonable doubt; juror credibility issues.	Evidence, including Rodrigues’s testimony and physical corroboration, supported conviction.	Evidence was legally sufficient; denial of new trial affirmed.

Cuyler v. Sullivan, 446 U.S. 335 (1980) (actual conflict adversely affecting counsel required for reversal)
Mickens v. Taylor, 535 U.S. 162 (2002) (actual conflict requires showing adverse effect; mere possibility is insufficient)
State v. Linde, 876 A.2d 1115 (R.I. 2005) (self-defense instruction required if even slight evidence supports theory)
State v. Butler, 107 R.I. 489 (1970) (self-defense instruction standard and interplay with charged conduct)
State v. Feng, 421 A.2d 1258 (R.I. 1980) (supervisory rule against mandatory prophylactic inquiries into conflicts)
Adams v. United States, 558 A.2d 348 (D.C. 1989) (fact pattern allowing self-defense instruction when weapon use is in issue)