State v. Jaythan Hang

Syllabus

The defendant, Jaythan Hang (defendant), appealed from a Superior Court judgment of conviction following a trial at which the jury found him guilty of murder in the first degree, conspiracy, two counts of felony assault, discharge of a firearm when committing a crime of violence, and four other firearms offenses. Before this Court, the defendant asserted that the trial justice abused her discretion (1) in denying a pretrial motion for severance; (2) in erroneously admitting evidence of prior bad acts and crime in the community under Rule 404(b) of the Rhode Island Rules of Evidence; (3) in erroneously admitting two statements as statements against interest pursuant to Rule 804(b)(3) of the Rhode Island Rules of Evidence; and (4) in allowing improper lay opinion testimony pursuant to Rule 701 of the Rhode Island Rules of Evidence; and that the trial justice clearly erred (5) in denying a motion for a new trial on the conspiracy count. The Supreme Court concluded that the trial justice appropriately considered the defendant's concerns for prejudice and weighed them against the need for judicial efficiency, and therefore she did not abuse her discretion in denying the defendant's motion for severance. The Supreme Court determined that the following issues were waived: defendant's argument concerning statements against interest pursuant to Rule 804(b)(3), his argument as to a portion of the prior bad-acts evidence admitted under Rule 404(b), and his argument that the trial justice allowed an improper lay opinion testimony pursuant to Rule 701. As to the prior bad-acts evidence that the defendant properly preserved on appeal, the Supreme Court held that the trial justice did not abuse her discretion in admitting the evidence for the state's proffered purpose of showing common scheme or plan and access to firearms. Finally, the Supreme Court concluded that the trial justice conducted the appropriate analyses on the defendant's motion for a new trial, and that she did not