State v. Stephen Mulcahey

Syllabus

The defendant, Stephen Mulcahey, appealed from a judgment of conviction, following a jury trial, for first-degree sexual assault, in violation of G.L. 1956 § 11-37-2. On appeal, the defendant argued that the trial justice erred in admitting a screenshot of text messages sent by the defendant to the victim after the assault. Specifically, the defendant argued that the state did not properly authenticate the evidence under Rule 901 of the Rhode Island Rules of Evidence because the state did not establish that the defendant authored the text messages. The Supreme Court concluded that the trial justice did not abuse his discretion in admitting the text message evidence because the evidence was properly authenticated. The Court held that the state, as the proponent of the evidence, had produced sufficient evidence to establish authorship and therefore properly authenticated the evidence in accordance with Rule 901. Accordingly, the Court affirmed the judgment of conviction.