Background
On the evening of May 14, 2021, Tyreik Grundy was shot and killed while seated in a Nissan Murano parked in a Providence, Rhode Island lot. An eyewitness described the shooter as wearing all black with a red hoodie, a COVID mask, and gloves, but no witness identified Quelon Page as the shooter. Police investigation produced three categories of circumstantial evidence linking Page to the crime: surveillance footage showing a distinctive white two-door Infiniti near the scene before and after the shooting — a vehicle Page was found driving four days later; cell site location analysis (CSLA) placing a cell phone connected to Page in the general area at the relevant time; and a DNA profile from a smudge on the rear passenger-side exterior window of the Murano that matched Page at a probability of one in 147 sextillion.
A Providence County Superior Court jury convicted Page on all four counts: first-degree murder, conspiracy to commit assault with a dangerous weapon, discharge of a firearm during a crime of violence resulting in death, and carrying a pistol without a license. Notably, during deliberations the jury asked whether Page could be guilty of murder if he had not personally fired the weapon; the trial justice instructed that the state was required to prove he fired the gun. Page was sentenced to two consecutive life terms, plus additional consecutive and concurrent sentences on the remaining counts.
Page moved for a new trial, arguing the verdict was against the fair preponderance of the evidence and that no evidence specifically established him as the shooter. The trial justice denied the motion after a bench ruling in which she found all state witnesses credible and concluded that the jury could reasonably infer Page’s DNA reached the Murano on the night of the murder when the shooter touched the vehicle. She nevertheless closed by stating that “reasonable minds could differ” in finding the state proved guilt beyond a reasonable doubt — without explaining the apparent tension between that conclusion and her earlier findings.
The Court’s Holding
The Rhode Island Supreme Court, in an opinion by Justice Long, vacated the trial justice’s denial of the motion for a new trial and remanded the case to the Superior Court for a new hearing. The Court held that the trial justice failed to adequately discharge her role as the “thirteenth juror” under the established four-step framework for evaluating new-trial motions based on the weight of the evidence. Specifically, the trial justice did not articulate whether she personally agreed or disagreed with the jury’s verdict, did not explain her own assessment of how the evidence and inferences should be weighed, and offered no rationale for why she found the evidence so nearly balanced that reasonable minds could differ.
The Court found the decision internally inconsistent: the trial justice had inferred that Page’s DNA reached the Murano on the night of the murder when the shooter contacted the vehicle and that Page was therefore the shooter, yet she simultaneously concluded — without explanation — that reasonable minds could differ on proof of guilt. That unresolved tension suggested she may not have agreed with the jury, which would have obligated her to proceed to step four of the analysis and determine whether the verdict was against the fair preponderance of the evidence and failed to do substantial justice. Because she made no such finding, remand was required so the trial justice could clearly articulate her personal assessment. Chief Justice Suttell dissented, concluding the trial justice’s analysis was sufficiently comprehensive and that he would have affirmed.
Key Takeaways
- A trial justice denying a motion for a new trial must state adequate grounds — including her own view of whether the evidence was so nearly balanced that reasonable minds could differ — and cannot simply defer to the jury without independently weighing the evidence as the “thirteenth juror.”
- An internally inconsistent decision (finding the defendant was the shooter, then concluding reasonable minds could differ without explanation) does not satisfy Rhode Island’s articulation requirement and warrants remand for a new hearing.
- In a wholly circumstantial case where the jury itself signaled uncertainty during deliberations, the trial justice’s obligation to articulate her reasoning is heightened.
- The remand is limited to a new hearing on the motion for a new trial, not a new trial itself; the conviction remains in place pending the Superior Court’s further proceedings.
Why It Matters
This decision reinforces Rhode Island’s demanding standard for trial justices acting as thirteenth jurors on new-trial motions. It makes clear that crediting the state’s witnesses and reciting the evidence is not enough — the court must also explain its own weight-of-the-evidence conclusion and, if it harbors doubt about the verdict, proceed through all four analytical steps. Defense practitioners can use the decision to challenge new-trial denials where the ruling is superficially thorough but lacks the justice’s personal assessment of whether the verdict was warranted.
The case also illustrates the limits of DNA evidence in a heavily circumstantial prosecution. Although the DNA match carried an astronomically low random-match probability, the defense raised credible questions about indirect transfer and the fact that witnesses described both assailants as wearing gloves — considerations the trial justice acknowledged but did not fully reconcile. How the Superior Court weighs those competing inferences on remand may determine whether Page receives a new trial.