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State v. Wray
38 A.3d 1102
R.I.
2012
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Background

  • 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)
Read the full case

Case Details

Case Name: State v. Wray
Court Name: Supreme Court of Rhode Island
Date Published: Mar 9, 2012
Citation: 38 A.3d 1102
Docket Number: 2010-209-C.A.
Court Abbreviation: R.I.