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