State v. Matthew Jones

Syllabus

The defendant, Matthew Jones, appealed from a judgment of conviction following a jury verdict of guilty on two counts of felony assault, in violation of G.L. 1956 § 11-5-2. The defendant advanced a single claim on appeal: that the trial justice abused his discretion by deviating from the law of the case doctrine and allowing the defendant's 1996 felony assault conviction to be introduced for impeachment purposes. The Supreme Court held that the trial justice did not abuse his discretion by allowing the state to impeach the defendant's credibility with the 1996 felony assault conviction. First, the Supreme Court concluded that the law of the case doctrine did not control the trial justice's decision because he was passing upon the admissibility of the 1996 felony assault conviction upon an expanded record and in the context of a new trial. Thus, the trial justice acted within the bounds of his discretion when he departed from a prior evidentiary ruling made pursuant to Rule 609 of the Rhode Island Rules of Evidence. Second, the Supreme Court concluded that the trial justice's admission of the 1996 felony assault conviction was proper pursuant to Rule 609. The defendant's long and continuous record of criminal behavior was probative as to his credibility as a witness, and thus the Supreme Court declined to disturb the trial justice's decision to admit the 1996 felony assault conviction. Accordingly, the Court affirmed the judgment of the Superior Court.