Tuesday, February 26, 2013

State v. Rose case brief

State v. Rose case brief summary
112 R.I. 402

SYNOPSIS: Defendant brought bills of exceptions challenging his convictions by the Rhode Island Superior Court after a jury trial on counts of leaving the scene of an accident, death resulting, in violation of R.I. GEN. LAWS § 31-26-1 (1968) and manslaughter after his motions for a new trial were denied.

FACTS:
-Defendant was convicted of leaving the scene of an accident, death resulting, in violation of R.I. GEN. LAWS § 31-26-1 (1968) and manslaughter following the death of a person struck by defendant's vehicle.
-After his motions for a new trial were denied, defendant brought bills of exceptions challenging his convictions.

HOLDING:
The appellate court affirmed his conviction for leaving the scene of an accident but reversed his manslaughter conviction and remanded the action for further proceedings.

ANALYSIS:
The court held that there remained a reasonable doubt as to defendant's innocence on the manslaughter charge because there was no evidence that defendant possessed the requisite culpable negligence either before or after his vehicle struck the victim. The court also held that the evidence was consistent with the finding of defendant's guilt on the leaving the scene of an accident charge and was not consistent with any other finding.

OUTCOME: The appellate court affirmed defendant's leaving the scene of the accident conviction, holding that the evidence could only be interpreted as establishing his guilt. The court reversed defendant's manslaughter conviction and remanded, holding that the requisite culpable conduct was not proven beyond a reasonable doubt.

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