State v. Roger Watkins
2014 R.I. LEXIS 95
| R.I. | 2014Background
- Jessica, a teenage household member, testified that defendant Roger Watkins (a parental figure and household disciplinarian) engaged in a multi-year pattern of sexual misconduct and assaults beginning in her mid-teens, including forced oral and vaginal intercourse and quid pro quo sex to remain in school.
- Defendant was arrested after a February 2010 school confrontation; he gave a recorded statement admitting many details that corroborated Jessica’s account.
- A Providence jury convicted Watkins of six counts of first-degree sexual assault and four counts of second-degree sexual assault; he was sentenced to 50 years (25 to serve, 25 suspended).
- On appeal Watkins challenged: (1) admission of evidence of uncharged prior acts ("play fighting") and an incident of corporal punishment; (2) portions of Dr. Amy Goldberg’s testimony recounting statements Jessica made during a medical/child-protection exam; and (3) the trial justice’s denial of his motion for a new trial.
- The Supreme Court reviewed admissibility under R.I. Evid. Rule 404(b) and Rule 403, and hearsay admissibility under Rule 803(4) (medical-treatment exception), and applied the deferential standard for new-trial rulings.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Watkins) | Held |
|---|---|---|---|
| Admissibility of "play fighting" (uncharged sexual touching) under Rule 404(b) | Evidence shows scheme/grooming and is relevant to intent and credibility of complainant | Evidence irrelevant to charged offenses, unfairly prejudicial and propensity-based | Admitted: court found it probative of intent/scheme; limiting instruction given; no abuse of discretion (affirmed) |
| Admissibility of corporal-punishment incident under Rule 404(b)/403 | Shows defendant’s disciplinarian role and establishes psychological coercion necessary to prove force element | Isolated non-sexual act; prejudicial and irrelevant to sexual assaults | Admitted: probative of control/coercion; balanced under Rule 403; no abuse of discretion (affirmed) |
| Admission of Dr. Goldberg’s testimony recounting complainant’s statements as Rule 803(4) hearsay exception | Statements about symptoms/fear and circumstances inform diagnosis/treatment for child-abuse evaluation | Statements were not shown to be made for treatment/diagnosis and thus inadmissible hearsay | Error to admit without adequate foundation; but error harmless because testimony was cumulative and corroborated by other evidence (affirmed) |
| Denial of motion for new trial (trial justice as 13th juror) | N/A (State opposed) | Trial justice overlooked or misconstrued exhibits (Garfield drawing, list of sexual acts) and verdict failed to do substantial justice | Denial affirmed: trial justice conducted independent review, found verdict supported by credible evidence (not clearly wrong) |
Key Cases Cited
- State v. Baptista, 894 A.2d 911 (R.I. 2006) (upholding admission of uncharged sexual acts to show scheme/intent)
- State v. Clay, 79 A.3d 832 (R.I. 2013) (standard of review for evidentiary rulings)
- State v. Martinez, 59 A.3d 73 (R.I. 2013) (Rule 404(b) principles; non-propensity purposes)
- State v. Burke, 522 A.2d 725 (R.I. 1987) (psychological coercion sufficient to satisfy force element)
- State v. Brigham, 638 A.2d 1043 (R.I. 1994) (admitting disciplinarian evidence to show control/coercion)
- State v. Gaspar, 982 A.2d 140 (R.I. 2009) (limits on causation statements under Rule 803(4))
- State v. Lynch, 854 A.2d 1022 (R.I. 2004) (foundation required for medical-treatment hearsay exception)
- State v. Haslam, 663 A.2d 902 (R.I. 1995) (improper bolstering by treatment counselor)
- State v. Robinson, 989 A.2d 965 (R.I. 2010) (harmless-error and cumulative-evidence analysis)