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State v. Robert Beaudoin
137 A.3d 726
| R.I. | 2016
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Background

  • Defendant Robert Beaudoin pled nolo contendere (June 2009) to felony assault and received 15 years with most suspended subject to probation.
  • State filed a Rule 32(f) probation-violation notice (May 14, 2012) alleging failure to keep the peace/be of good behavior; police reports referenced allegations of sexual assault and robbery/larceny.
  • Violation hearing (three days, July 2012) centered on events of May 9, 2012: complainant Matthew (history of traumatic brain injury, treated at RHD) testified that Beaudoin locked a bedroom door, showed weapons, groped him, and demanded $50 at gunpoint; Matthew later reported the incident to RHD staff and police.
  • Defense witnesses (family members, defendant) denied ownership of guns/daggers, explained the encounter as a sale of a sword for $20–$50, and denied any groping or extortion; officers testified to Matthew’s contemporaneous statement describing groping and weapons.
  • Hearing justice credited Matthew’s testimony (finding him limited but candid and inconsistencies explainable by his injury), discredited the defendant’s sale-explanation as "nonsensical," concluded Beaudoin at least took Matthew’s money, and found a probation violation. Court imposed two years of the previously suspended sentence (balance suspended).

Issues

Issue Plaintiff's Argument (State) Defendant's Argument (Beaudoin) Held
Whether reasonably satisfactory evidence supported finding violation of probation (failure to keep the peace/be of good behavior) Evidence (Matthew’s testimony and police statements) was sufficient under the lower probation-violation standard Hearing justice erred; findings were arbitrary/capricious and unsupported by the record, especially given inconsistencies in Matthew’s statements and disputed money transfer Affirmed — court applied deferential standard and found hearing justice reasonably satisfied a violation occurred
Whether hearing justice improperly resolved credibility (inconsistencies and explanation by injury; finding that defendant took money) Hearing justice properly weighed demeanor and explained why inconsistencies were explainable; findings were supportable Credibility findings contradicted record; conclusion that defendant took money is not supported by evidence Affirmed — appellate court will not second-guess supportable credibility assessments and found no arbitrary or capricious action

Key Cases Cited

  • State v. Prout, 116 A.3d 196 (R.I. 2015) (probation-violation burden is lower than beyond a reasonable doubt)
  • State v. Barrientos, 88 A.3d 1130 (R.I. 2014) (hearing justice weighs evidence and assesses credibility in probation revocation)
  • State v. Raso, 80 A.3d 33 (R.I. 2013) (standard of review: whether hearing justice acted arbitrarily or capriciously)
  • State v. Ford, 56 A.3d 463 (R.I. 2012) (credibility assessment and fact-finding role of hearing justice)
Read the full case

Case Details

Case Name: State v. Robert Beaudoin
Court Name: Supreme Court of Rhode Island
Date Published: Apr 26, 2016
Citation: 137 A.3d 726
Docket Number: 2012-325-C.A.
Court Abbreviation: R.I.