State v. Quandell Husband, 162 A.3d 646

Background

On July 30, 2012, three people (Michael Martin, Damien Colon, Shameeka Barros) were killed during an attempted robbery in Providence; 17 9mm shell casings were recovered.
Quandell Husband, age 16 at the time, was adjudicated in Family Court and waived to Superior Court; he was later indicted and tried as an adult for three counts of first‑degree murder, three counts of using a firearm during a crime of violence, and one count of conspiracy to commit robbery.
The State’s case relied on cooperating witnesses (Hall and Burrell), eyewitnesses who placed Husband near the scene, testimony that Husband had possessed a 9mm Glock roughly a month earlier, and jailhouse statements attributed to Husband.
Burrell pleaded guilty to related charges and gave varying statements to police; the State’s theory at trial included vicarious liability (aider/abettor) even after the State’s theory shifted toward Burrell as the shooter.
Husband was convicted on all counts and sentenced to consecutive and concurrent long terms; he appealed arguing errors in the Family Court waiver process and evidentiary rulings at trial.
The Rhode Island Supreme Court vacated the convictions and remanded for a new trial, finding that the trial court abused its discretion by admitting highly prejudicial evidence about an unrelated shooting (the Ellerbe shooting).

Issues

Issue	State's Argument	Husband's Argument	Held
Family Court waiver review	Waiver appropriate given probable cause, heinous/premeditated offenses and public protection	Waiver focused on charge label rather than Husband’s specific conduct; failed to consider rehabilitation and new evidence shifting shooter theory	Waiver upheld: Family Court’s prong‑two analysis was supported by the evidence and it lacked authority to reopen waiver absent acquittal
Consideration of defendant’s Miranda/interrogation statements at waiver	Statements were part of the record and were listened to by the court	Statements were involuntary because mother present but not allowed to invoke rights; therefore inadmissible	No reversible error: Family Court gave little or no weight to the statements; claim not preserved as suppression hearing not sought
Admission of evidence that Husband possessed the murder weapon earlier (Anderson testimony)	Relevant to identity, access to weapon, and participation in conspiracy	Highly prejudicial and suggested bad character/past crimes	Admission not an abuse of discretion: probative of access/opportunity and relevant to conspiracy/vicarious liability
Admission of evidence about the Ellerbe shooting (unrelated victim shot by DeBritto with same gun)	Shows the Glock was a "community gun" linking DeBritto, Burrell, and others; corroborates relationships among actors	Marginally relevant to Husband; highly prejudicial and likely to confuse jury by suggesting involvement in another violent crime	Admission was an abuse of discretion under Rule 403: marginal probative value and enormous prejudice; error was not harmless and requires vacatur and a new trial

Key Cases Cited

State v. Day, 911 A.2d 1042 (R.I. 2006) (standard and factors governing Family Court waiver of juvenile jurisdiction)
State v. Rios, 996 A.2d 635 (R.I. 2010) (evidence that defendant frequently carried a gun is relevant to identity and opportunity)
State v. Lynch, 854 A.2d 1022 (R.I. 2004) (definition and treatment of cumulative evidence)
State v. Hak, 963 A.2d 921 (R.I. 2009) (Rule 403 exclusion should be exercised sparingly)
State v. Patel, 949 A.2d 401 (R.I. 2008) (only marginally relevant and enormously prejudicial evidence must be excluded)
State v. Burke, 427 A.2d 1302 (R.I. 1981) (relevance inquiry and prejudice concerns under evidentiary rules)
State v. Pona, 66 A.3d 454 (R.I. 2013) (Rule 404(b) standard for admitting other‑acts evidence)