State v. Snell
11 A.3d 97
R.I.2011Background
- Snell attacked Eisom and Edmonds in January 2001, injuring both with a knife and a boot stomp.
- He was charged in March 2001 with four counts; convicted on all counts on December 11, 2001.
- On March 22, 2002, he received a total sentence of 45 years with 30 to serve; 15 years suspended with probation.
- Snell moved for Rule 35(a) relief in May 2006, arguing departure from sentencing benchmarks and illegality of consecutive sentences; the State sought an increase under Rule 35(b).
- The trial justice denied the motions on October 1, 2007, reaffirming the upward departure and the consecutive sentences.
- The Rhode Island Supreme Court affirmed, holding the sentences were justified and not grossly disproportionate.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the departure from sentencing benchmarks was justified | Snell contends life-threatening injuries were falsely characterized to justify a heavy, benchmark-exceeding sentence. | Snell argues the injuries were not life-threatening and the sentence should be reduced accordingly. | Yes; sentences upheld as proportionate given aggravating factors beyond injuries. |
| Whether consecutive sentences were appropriate | Snell contends consecutive terms for separate victims were improper without extraordinary circumstances. | Snell argues consecutive terms were unwarranted because of Ballard-like guidance. | Yes; the consecutive sentences were properly supported by two distinct assaults and explained by the trial justice. |
| Whether the State could seek an increased sentence under Rule 35(b) | State sought a sentence increase based on disciplinary history and lack of rehabilitation. | Snell argues the court should not increase the sentence after denying the reduction. | Yes; the State’s motion to increase was denied consistent with the record. |
Key Cases Cited
- State v. Ruffner, 5 A.3d 864 (R.I. 2010) (motion to reduce is reviewed for abuse of discretion)
- State v. Coleman, 984 A.2d 650 (R.I. 2009) (upholds departures from benchmarks based on aggravating factors)
- State v. Bettencourt, 766 A.2d 391 (R.I. 2001) (benchmarks guide proportionality; not mandatory)
- State v. Ballard, 699 A.2d 14 (R.I. 1997) (Ballard overruled as bright-line rule for consecutive sentences)