State v. Enos

Charges were filed against a young woman’s ex-boyfriend for domestic violence after he grabbed her at a restaurant and repeatedly kicked her and hit her over the head with a drinking glass. The defendant was convicted in the lower court of domestic assault with a dangerous weapon. On appeal, the defendant argued that there was insufficient evidence that the couple was in a domestic relationship, which was a prerequisite finding for his conviction. The Rhode Island Supreme Court held that the state domestic violence statute does not require a specific demonstration of three statutory factors (length and nature of relationship and frequency of the interaction between the parties) to prove the existence of a substantive dating relationship, nor are courts limited to considering only these three factors. Rather, the fact that the victim testified that (i) the couple dated for six months, (ii) the two had an intimate relationship during the defendant’s arrest, and (iii) the defendant referred to the victim as his girlfriend was evidence that the defendant and the victim were in a substantive dating relationship as required to support a domestic assault conviction. The Court also rejected the defendant’s arguments regarding the trial judge’s decision not to declare a mistrial and upheld his conviction.