State v. Michael DeCosta

Syllabus

The defendant, Michael DeCosta, appealed from a judgment of conviction entered by the Superior Court after a jury found him guilty of felony assault resulting in serious bodily injury in violation of G.L. 1956 § 11-5-2. He was thereafter sentenced to a term of twenty years at the Adult Correctional Institutions, required to undergo a substance abuse evaluation and treatment, anger management and counseling, and subject to a no-contact order. On appeal, the defendant contended that the trial justice erred in admitting evidence that the defendant struck an unrelated person in an unrelated event earlier in the night, in violation of Rules 404(b) and 403 of the Rhode Island Rules of Evidence. <br><br>The Supreme Court determined that there was no evidence to suggest that the defendant hitting another person earlier in the evening had any connection to the defendant's plan, intent, or scheme towards the complaining witness in this case and, therefore, that the trial justice abused his discretion in admitting the statement. Nevertheless, the Supreme Court held that the overall strength of the prosecution's case was robust, such that the admission of this statement under the trial justice's instruction would not influence an average jury on the question of guilt. Therefore, the Supreme Court concluded that the admission of the statement amounted to harmless error. <br><br>Accordingly, the Court affirmed the judgment of the Superior Court.