State v. Staffier, 2011 R.I. LEXIS 79

Staffier was convicted on three counts of second-degree child molestation and acquitted on one count after a jury trial.
Harriet, a minor, testified about ongoing molestation by Staffier from around age seven or eight through 2002.
The trial court denied Staffier's motion for a new trial; he challenged the verdicts as inconsistent and the admission of a rebuttal witness.
Staffier argued the inconsistent verdicts did not do substantial justice, warranting a new trial, and that the rebuttal witness violated sequestration.
The trial court found the three guilty counts supported by credible child-witness testimony and that the acquittal on one count did not render others inconsistent.
On appeal, the Rhode Island Supreme Court affirmed, holding no abuse of discretion in denying the new trial and admitting the rebuttal witness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denial of motion for a new trial was correct	Staffier argues inconsistent verdicts fail to do substantial justice.	Staffier contends the not-guilty verdict on count 1 shows logical/legal inconsistency.	No reversible error; verdicts viewed separately supported conviction on three counts.
Whether the rebuttal witness violated sequestration rules	John's testimony was improperly admitted despite sequestration.	Any violation was unintentional and testimony addressed credibility concerns.	Court did not abuse discretion; testimony properly allowed given context and limited prejudice.

State v. Peoples, 996 A.2d 660 (R.I.2010) (new-trial standard—thirteenth juror approach)
State v. Stone, 924 A.2d 773 (R.I.2007) (reasonable-doubt standard on new-trial motion)
State v. Heredia, 10 A.3d 443 (R.I.2010) (credibility assessment on review of new-trial motion)
State v. Imbruglia, 913 A.2d 1022 (R.I.2007) (independent credibility weighing by trial court)
State v. Guerra, 12 A.3d 759 (R.I.2011) (substantial-justice standard after initial disagreement with verdict)
Rivera, 839 A.2d 497 (R.I.2003) (fourth-step substantial-justice analysis for new trials)
Allessio, 762 A.2d 1190 (R.I.2000) (verdicts on separate counts not required to be consistent)
Jette, 569 A.2d 438 (R.I.1990) (acquittal on one count does not negate others)
State v. Burke, 522 A.2d 725 (R.I.1987) (retroactive rebuttal testimony and sequestration considerations)
State v. Perez, 882 A.2d 574 (R.I.2005) (sequestration decisions reviewed for abuse of discretion)
State v. Mathias, 423 A.2d 484 (R.I.1980) (sequestration purpose to prevent shaping testimony)
State v. Cyrulik, 100 R.I. 282 (R.I.1965) (sequestration policy origin cited)