Permissibility of Lay Vehicle Identification and Prior Bad Acts Evidence: State v. Chandanoeuth Hay

Introduction

State v. Chandanoeuth Hay was decided by the Supreme Court of Rhode Island on May 29, 2025. The defendant, Chandanoeuth Hay, was convicted of ten counts arising from a fatal shooting on June 26, 2018, that claimed the life of David Page in Providence. At trial, the State relied on surveillance video evidence, testimony from a cooperating witness with gang-related background, lay opinion from a police sergeant about the make of a vehicle, and numerous “prior bad acts” to establish motive, intent, and access to firearms. On appeal, Hay challenged four evidentiary rulings:

Admitting a police sergeant’s lay opinion that the vehicle in surveillance footage was “consistent with an Audi.”
Denying a Franks v. Delaware hearing about alleged misstatements in a search‐warrant affidavit.
Allowing testimony by the cooperating witness about unrelated shootings and gang membership under Rule 404(b).
Permitting photographs showing Hay holding firearms and making hand gestures.

The Supreme Court unanimously affirmed the Superior Court’s judgment of conviction and commitment, clarifying when lay opinion testimony and prior‐bad‐acts evidence are admissible, and emphasizing the limited scope of a Franks hearing.

Summary of the Judgment

The Court reached four key conclusions:

Lay Opinion on Vehicle Identification: A seasoned video‐forensics sergeant may offer a lay opinion that a dark sedan in grainy surveillance footage is “consistent with an Audi,” provided his opinion is based on personal perception (frame‐by‐frame analysis, comparison to known images) and is helpful to the jury. The Court likened this to opinion testimony in State v. Doyle, 235 A.3d 482 (R.I. 2020).
Franks Hearing: Defendant failed to make a “substantial preliminary showing” that Detective Michael knowingly or recklessly inserted false statements in the warrant affidavit. Even excluding the challenged statements, sufficient other material supported probable cause to search Hay’s phone, so no Franks hearing was required.
Rule 404(b) Evidence of Prior Shootings and Gang Affiliation: Testimony by the cooperating witness regarding prior drive-by shootings, discussions of retaliation, and the killing of a gang associate was admissible to show common plan, motive, intent, access to firearms, and absence of accident. The Court found no abuse of discretion in admitting that evidence, especially given the trial justice’s cautionary limiting instructions and the exclusion of more prejudicial materials.
Photographic Evidence: Photographs depicting Hay with handguns and gang‐associated hand gestures were relevant to show his relationship with the cooperating witness and his familiarity with firearms. The probative value outweighed any danger of unfair prejudice.

The judgment was affirmed in all respects.

Analysis

Precedents Cited

Franks v. Delaware (438 U.S. 154, 1978): Defendant must make a substantial preliminary showing of intentional or reckless falsehood in a warrant affidavit to trigger a hearing.
Daubert v. Merrell Dow Pharmaceuticals (509 U.S. 579, 1993): Standards for expert testimony, distinguishing expert versus lay opinion.
State v. Doyle (235 A.3d 482, R.I. 2020): Admitted lay opinion by a fraud‐examiner detective on credit‐card expenditures; jury did not need every underlying document.
State v. Ortiz (609 A.2d 921, R.I. 1992) and State v. Mann (889 A.2d 164, R.I. 2005): Lay‐opinion test—opinion must be based on perception and helpful to the jury.
State v. Jimenez (882 A.2d 549, R.I. 2005) and State v. Pratt (641 A.2d 732, R.I. 1994): Scope and limitations on admission of prior bad acts under Rule 404(b).
State v. Rios (996 A.2d 635, R.I. 2010): Evidence a defendant frequently carried a handgun was admissible to show access to a weapon.
Rhode Island Rules of Evidence 401, 403, 404(b), 701–702: Framework for relevance, balancing probative value versus unfair prejudice, and opinion testimony.

Legal Reasoning

1. Lay Opinion Testimony: The Court held that Sergeant Primiano’s lay opinion on vehicle make was admissible under Rule 701 because:

He had direct, prolonged perception of the footage via specialized video‐forensics software.
He compared surveillance images to known Audi images and the seized car.
The opinion assisted the jury in connecting the car at the shooting scene to the later-recovered stolen Audi.

2. Franks Hearing: No “intent to deceive” or “reckless disregard” was shown concerning Detective Michael’s affidavit statements. Striking the challenged lines still left abundant grounds—cooperating‐witness testimony and stolen‐car records—to establish probable cause.

3. Rule 404(b) Evidence: The trial justice acted within her discretion in finding a proper non-propensity purpose—motive, plan of gang retaliation, access to firearms, absence of accident—for introducing prior‐shooting testimony. She also conducted an informal Rule 403 analysis by excluding even more prejudicial items and giving repeated limiting instructions.

4. Photographs: Images of Hay with handguns and gang gestures were relevant to show his close association with the cooperating witness and his familiarity with firearms. Any tendency to inflame was outweighed by evidentiary value, especially with jury instructions limiting their use.

Impact

This decision provides trial judges and litigators with clearer guidance on:

Admitting lay opinions on technical subjects (e.g., vehicle make) when the witness’s perceptions and methods exceed ordinary juror review.
Applying the Franks standard strictly—overstatements in an affidavit do not require a hearing absent proof of deceptive intent or reckless falsity.
Using prior‐bad‐acts evidence sparingly under Rule 404(b), but acknowledging that interwoven patterns of gang violence may be essential to paint a coherent factual narrative.
Balancing the probative value of graphic or gang-related images against unfair prejudice under Rule 403, with limiting instructions as a safety valve.

Future criminal trials—especially those involving gang violence, surveillance evidence, and disputed search warrants—will rely on this ruling to navigate the evidentiary boundaries.

Complex Concepts Simplified

Lay vs. Expert Opinion (Rules 701–702): A lay witness may give an opinion based on personal observation when it helps the jury (e.g., “that looked like an Audi”). Expert testimony, by contrast, requires specialized qualifications and pretrial admissibility hearings (Daubert).
Franks Hearing: A defendant can challenge a warrant affidavit only by showing a deliberate or reckless falsehood that was essential to finding probable cause—otherwise the warrant stands.
Rule 404(b) Evidence: Prior crimes or bad acts are generally inadmissible to show character or propensity. They may be admitted, however, to prove motive, plan, intent, or knowledge, subject to a balancing test under Rule 403.
Rule 403 Balancing: Even relevant evidence can be excluded if its potential for unfair prejudice substantially outweighs its true probative value. A limiting instruction can mitigate the jury’s misuse of such evidence.

Conclusion

State v. Hay reaffirms that:

Qualified lay witnesses may provide technical opinions when based on firsthand analysis that aids jurors’ understanding.
Franks challenges require proof of deliberate or reckless falsity, not just overstatement.
Rule 404(b) evidence of gang violence may be critical to show intent and plan, so long as judges exclude unduly prejudicial material and give proper jury instructions.
Photographs of weapons and gang symbols carry probative weight when they illustrate relationships and routine access to firearms.

The Supreme Court’s decision, therefore, clarifies and constrains the use of lay opinions, Franks hearings, and prior‐bad‐acts evidence, ensuring that criminal trials remain fair while respecting the probative needs of the prosecution.