Supreme Court of Rhode Island
State v. Jairo Esdel
July 15, 2024
Summary
The Rhode Island Supreme Court vacated Jairo Esdel’s second‑degree murder conviction, holding that the trial court erred by refusing a voluntary manslaughter instruction and by excluding the defendant’s grandfather’s testimony about a threat, while finding the exclusion of 2018 pistol‑whipping testimony harmless and affirming the exclusion of a WhatsApp video pending proper authentication. The Court remanded for a new trial on the murder and manslaughter charges and for a hearing on the video’s authenticity.