Angell v. State – Case Brief Summary (Rhode Island)

In Angell v. State, 454 A.2d 709 (R.I. 1983) the defendant filed an ineffective assistance of counsel claim against his trial and appellate attorney outlining numerous tactical mistakes allegedly made during the course of his murder trial.

The most significant testimony produced at trial, in addition to the circumstantial evidence centering on the victim's death, came from the defendant's wife. Id.

Although the defendant proposed several tactical approaches that his trial counsel did not employ, the court was satisfied that those proffered maneuvers would not have affected the outcome of the case. Id. The basis for the Court's conclusion was the testimony of the defendant's wife.

The Court was convinced that this testimony had been the "heart of the state's presentation . . . Nothing suggested by present counsel . . . would have shaken or diminished the force of that testimony. . . . The defendant's wife's testimony made it virtually impossible for any defense counsel, however skillful, to defend the defendant successfully." Id. at 710.