State v. Richardson
47 A.3d 305
| R.I. | 2012Background
- Margaret Duffy-Stephenson was murdered in her Rhode Island home; evidence pointed to a non-random break-in with knowledge of the residence and its safe.
- The State’s physical evidence included DNA underneath Margaret’s fingernails and hair/mixed-DNA samples; the victim’s nails showed mostly Margaret’s DNA with a male mixture at nail five.
- Defendant James S. Richardson had prior access to the Stephenson home and knew the location of the basement safe; he had worked for the family and returned from the Philippines in October 2005.
- Detective and lab testimony showed DNA and transfer evidence, with Mallard as the DNA expert and Ladd later offering independent analysis based on Mallard’s data and worksheets.
- A prison-cell mate, Trimarco, testified that Richardson admitted stabbing the victim and described plans to rob the house and locate the safe; other witnesses corroborated circumstances around the crime scene.
- Richardson was convicted of first-degree murder and burglary and sentenced to life without parole; he appealed on evidentiary and procedural grounds, including bolstering and acquittal/new-trial motions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Dr. Ladd’s testimony constituted bolstering of Mallard | Richardson argues Ladd’s testimony bolstered Mallard’s credibility. | Richardson contends Ladd merely restated Mallard’s conclusions without independent analysis. | No reversible error; Ladd’s testimony relied on objective data and did not improperly bolster Mallard. |
| Sufficiency of evidence for judgment of acquittal and for a new trial | State contends evidence supported guilt beyond reasonable doubt. | Richardson argues insufficient evidence; asks for acquittal or new trial. | Trial court properly denied acquittal; new-trial denial affirmed; substantial evidence supported guilt. |
Key Cases Cited
- State v. St. Michel, 37 A.3d 95 (R.I.2012) (abuse-of-discretion standard for evidentiary rulings; prejudice review)
- State v. Johnson, 13 A.3d 1064 (R.I.2011) (standard on reviewing evidentiary rulings)
- State v. Brown, 9 A.3d 1232 (R.I.2010) (standard for Rule 29 acquittal review)
- State v. Cerda, 957 A.2d 382 (R.I.2008) (new-trial standard; independent credibility assessment)
- State v. Pineda, 13 A.3d 623 (R.I.2011) (new-trial/ acquittal standards; thirteenth juror concept)
- State v. Amyo, 844 A.2d 163 (R.I.2004) (two experts; bolstering analysis framework)
- State v. Rushlow, 32 A.3d 892 (R.I.2011) (bolstering analysis; admissibility when based on objective data)