State v. Wray
38 A.3d 1102
R.I.2012Background
- Two women were robbed at gunpoint in Providence on Jan 27, 2006; Wray was convicted of two counts of first-degree robbery.
- Eyewitnesses Rashida Lovett and Toni Matthews identified Wray; inconsistencies existed but jury convicted.
- Matthews identified Wray from a six-photo array two days after the robbery.
- Detective Melaragno testified about investigation and related arrest; another man (Ferreira) was implicated as white male, car linked.
- Defense moved for a new trial arguing unreliable identifications; trial court denied; Wray sentenced to 20 years with 10 years to serve on each count.
- Appellate court affirmed, holding no reversible error in the denial of the motion or in the bolstering ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of the motion for a new trial was proper given identifications. | State: two credible identifications; trial judge acts as thirteenth juror. | Wray: identifications unreliable; inconsistencies undermine reliability. | No error; denial affirmed; evidence supported guilt. |
| Whether Detective Melaragno's testimony constituted impermissible bolstering of eyewitnesses. | State: description-based testimony aids probable cause and is permissible. | Wray: bolstering invaded jury's province by endorsing identifications. | Not impermissible bolstering; testimony within officer duties; no prejudicial error. |
Key Cases Cited
- State v. Prout, 996 A.2d 641 (R.I. 2010) (thirteenth juror standard for motions for new trial)
- State v. Cerda, 957 A.2d 382 (R.I. 2008) (independent credibility and weight assessment by judge)
- State v. Bergevine, 942 A.2d 974 (R.I. 2008) (credibility and weight of evidence in new-trial review)
- State v. Guerra, 12 A.3d 759 (R.I. 2011) (deference to trial judge’s credibility determinations)
