State v. Washington, 42 A.3d 1265

Washington was on a five-year term of imprisonment with a ten-year probation following his 2005 plea to assault with intent to commit certain felonies.
In March 2009, Washington was arrested on charges including felony assault with a dangerous weapon and assault with intent to commit sexual assault, leading to a Rule 32(f) probation-violation filing.
The probation-violation hearings on May 6–7, 2009 featured eyewitness testimony from Carrie Banner and Joanne Kane, plus police detective testimony and defense witnesses.
Banner identified Washington from photographs and in court as her attacker, noting hairstyle differences but maintaining recognition from prior descriptions.
Kane and Detective Tuffy also identified Washington from photo arrays; Washington testified in his own defense and his relatives corroborated his whereabouts.
The hearing justice found Banner’s testimony credible and concluded Washington violated the probation terms, ordering the previously suspended ten-year sentence to be served; Washington sought certiorari.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the eyewitness identification reliable to sustain a probation violation?	Banner's identification, corroborated by Kane and in-court ID, was reliable.	The identification raised questions about reliability due to hairstyle changes and other inconsistencies.	Yes; the court upheld the reliance on the eyewitness identifications.
Did the trial justice act arbitrarily in weighing credibility of witnesses?	Credibility determinations favored the prosecution and were reasonable.	Family testimony was biased and less credible; the judge should not have given weight to the eyewitnesses.	No; the credibility determinations were reasonable and supported the finding of a violation.
Did the evidence as a whole reasonably support a probation-violation finding given the standard of proof at such hearings?	Reasonable evidence supported a violation given the witness identifications and corroborating testimony.	The record contained questions about identification reliability and defendant's alibi.	Yes; the record provided plausible grounds to conclude a probation violation.

State v. Jensen, 40 A.3d 771 (R.I. 2012) (great deference to trial judge credibility determinations)
State v. Seamans, 935 A.2d 618 (R.I. 2007) (probation-violation credibility review)
State v. Horton, 971 A.2d 606 (R.I. 2009) (burden of proof in probation hearings)
State v. Shepard, 33 A.3d 158 (R.I. 2011) (credibility assessment in probation context)
State v. Tetreault, 973 A.2d 489 (R.I. 2009) (credibility and evidence standard in probation context)
State v. Bouffard, 945 A.2d 305 (R.I. 2008) (lower burden of proof in probation violations)