William Lamont Thomas v. Omar Proctor, 63 A.3d 881

Thomas was shot by Officer Proctor during a December 20, 2004, arrest attempt and sued for damages.
The trial centered on whether Proctor acted reasonably when he fired; the jury returned for Proctor.
The court admitted a redacted Known Persons Intelligence Report about Thomas, including a mug shot and a 1992 shotgun arrest, with other arrests redacted.
Plaintiff objected that the report was prejudicial because the shotgun charge was dismissed and not a conviction.
The court ordered redaction of non-pertinent arrest information and allowed the mug shot with the firearm reference, with a curative instruction later given to the jury.
The Rhode Island Supreme Court affirmed, holding the trial court did not abuse its discretion in admitting the redacted report.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the redacted police database report was admissible	Thomas argues the report was highly prejudicial and not probative because the shotgun charge was dismissed	Proctor needed the report to show what he believed at the time; it supported reasonableness	No abuse of discretion; admissible with redactions

State v. Dinagen, 639 A.2d 1353 (R.I. 1994) (mug-shot prejudice risks and admissibility guidance in criminal context)
State v. Bowden, 439 A.2d 263 (R.I. 1982) (harmless or non-prejudicial impact of improper evidence)
State v. Robertson, 740 A.2d 330 (R.I. 1999) (prejudicial effect mitigated when evidence arises from multiple sources)
State v. DeJesus, 947 A.2d 873 (R.I. 2008) (Rule 403 balancing; discretion in evidentiary rulings)
State v. Tetreault, 31 A.3d 777 (R.I. 2011) (standard for reviewing evidentiary rulings for abuse of discretion)
State v. Dellay, 687 A.2d 435 (R.I. 1996) (limitations on admissibility of prejudicial evidence)
State v. Lemon, 456 A.2d 261 (R.I. 1983) (three criteria for mug-shot admissibility in criminal cases)