State v. Joseph Lamontagne

Syllabus

The defendant, Joseph Lamontagne, was found guilty by a jury of first-degree robbery and assault with a dangerous weapon. Before the start of the defendant's trial, the state filed a motion in limine to prevent the defendant from introducing the prior convictions of the complaining witness. The trial justice made a preliminary ruling that the defendant could introduce two of these convictions under Rule of Evidence 609. The trial justice revisited this ruling during the trial and precluded the defendant from introducing the convictions. Prior to the close of his case, the defendant sought to introduce photographs into evidence which were taken nearly two weeks after the robbery and assault and purported to show bruises he allegedly sustained during the incident that led to his arrest. The state objected, and the trial justice sustained the state's objection. On appeal, the defendant argued that the trial justice abused her discretion by denying the admission of the convictions because, according to the defendant, the case hinged on the witness's credibility and the convictions' probative value outweighed its' prejudicial effect. The defendant further contended that the photographs should have been admitted because whether they supported his claim of self-defense was a matter of the weight of the evidence and not its admissibility. The Supreme Court held that the trial justice did not abuse her discretion in excluding evidence of the complaining witness's two prior convictions. The Supreme Court also held that the trial justice did not abuse her discretion in excluding the photographs Accordingly, the Supreme Court affirmed the defendant's judgment of conviction.