State v. Tetreault, 2011 R.I. LEXIS 136

Defendant William Tetreault was charged in 2003 and tried in 2006 on five felony counts—two first-degree sexual assaults, two felony assaults, and a larceny—resulting in convictions and concurrent sentences totaling up to 30 years.
Teresa, the complainant and girlfriend of the defendant, testified about a brutal assault and sexual contact; the defense admitted some acts but denied sexual assault and sought to challenge Teresa’s credibility.
Investigating officers initially learned Teresa described the attack as occurring in public; later, surveillance photos from an ATM showed Tetreault present when Teresa used the card, prompting further police interviews.
Teresa’s account evolved after police confronted her with ATM evidence, leading to detailed testimony at trial describing the assault in her apartment and the coercive conduct by Tetreault.
The defense elicited testimony from the defendant admitting to some physical violence but denying sexual assault and burning with a cigarette, while alleging Teresa fabricated parts of the story.
On appeal, the Supreme Court upheld the trial court’s decisions—excluding Detective Nowak’s opinion testimony about Teresa’s truthfulness and admitting most of Tetreault’s prior convictions for impeachment—finding no abuse of discretion under Rules 608, 403, and 609.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Det. Nowak could testify about Teresa’s truthfulness	State contends Nowak’s opinion was marginally relevant and outweighed by prejudice concerns.	Tetreault argues Nowak’s opinion about credibility was improperly excluded and highly probative.	No abuse of discretion; testimony excluded as marginal relevance and potentially prejudicial.
Whether admitting eleven of defendant's prior convictions violated Rule 609	State asserts the convictions bear on credibility given lengthy criminal history.	Tetreault contends convictions are too remote and prejudicial to be probative.	No abuse of discretion; convictions admitted with limiting instruction.

State v. Dellay, 687 A.2d 435 (R.I. 1996) (standard to review evidentiary rulings for abuse of discretion)
State v. Silvia, 898 A.2d 707 (R.I. 2006) (Rule 609 impeachment discretion; breadth of law in Rhode Island)
State v. Rodriquez, 731 A.2d 726 (R.I. 1999) (deference to trial court on evidentiary decisions)
State v. Mattatall, 603 A.2d 1098 (R.I. 1992) (remoteness and probative value of prior convictions for impeachment)
State v. Remy, 910 A.2d 793 (R.I. 2006) (considerations for admissibility of prior convictions under Rule 609)
State v. Sands, 386 A.2d 378 (N.J. 1978) (jury may consider pattern of conduct in credibility assessments)