State v. Thomas H. Matthews
111 A.3d 390
| R.I. | 2015Background
- Matthews was arrested January 31, 2012 in Middletown and charged with disorderly conduct under § 11-45-1(a)(3) for directing offensive words at officers in a public place.
- Prosecution presented Trooper Washington and Trooper Viera who testified Matthews threatened and insulted them during arrest and attempted to escalate the confrontation.
- Defense moved for judgment of acquittal arguing the speech was protected First Amendment expression; the trial court denied the motion.
- Matthews moved for a new trial asserting the evidence was insufficient and the trial court erred in denying the Rule 29 judgment of acquittal; the trial court denied the motion.
- Jury found Matthews guilty after trial; sentence was six months with thirty days to serve and the balance suspended with probation.
- Appellate court affirmed, holding the trial court properly denied the new trial and acquittal motions and the complaint properly alleged the offense.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred in denying a new trial. | Matthews argues the speech did not rise to fighting words. | State contends the speech meets the fighting-words standard under § 11-45-1(a)(3). | Denied; trial court properly affirmed the verdict. |
| Whether Matthews’ speech violated fighting-words doctrine under the First Amendment. | Matthews maintains the utterances were protected and not fighting words. | State asserts the context shows direct targeting of officers and likelihood of immediate breach of peace. | Affirmed; speech found to be fighting words under the statute. |
| Whether the criminal complaint sufficiently notified Matthews of the charge despite subsections confusion. | Complaint referenced multiple subsections, potentially undermining notice. | Defendant received adequate notice; instructions tracked the fighting-words standard. | Not preserved for review; the issue was not properly raised below. |
Key Cases Cited
- Chaplinsky v. New Hampshire, 315 U.S. 568 (U.S. 1942) (fighting words defined as words likely to provoke immediate breach of the peace)
- McKenna, 415 A.2d 729 (R.I. 1980) (fighting words analysis with attendant circumstances)
- Authelet, 120 R.I. 42, 385 A.2d 642 (R.I. 1978) (objective test: words directed to an average person likely to cause violence)
- Johnson v. Palange, 122 R.I. 361, 406 A.2d 360 (R.I. 1979) (fighting words defined; words directed to police may still be fighting words)
- McKenna, 415 A.2d 729 (R.I. 1980) (bystander context; not fighting words when not directed at officers individually)
- State v. Hie, 93 A.3d 963 (R.I. 2014) (thirteenth-juror standard for new-trial review; weighing credibility)
- State v. Richardson, 47 A.3d 305 (R.I. 2012) (standard for new-trial weight of evidence and credibility of witnesses)
- State v. Robat, 49 A.3d 58 (R.I. 2012) (appellate review of new-trial ruling; required standards of analysis)