## Facts

- Michael R. Grayhurst and Jane Grayhurst divorced after a deteriorating relationship; Jane obtained District Court no-contact orders prohibiting Grayhurst from harassing or threatening her.
- While incarcerated, Grayhurst sent Jane repeated mailings (cards, letters, pamphlets, clippings) that included threats against her and various public officials, including judges.
- After Jane reported the correspondence to authorities, outgoing mail from Grayhurst to Jane was monitored.
- During a Family Court proceeding related to the sale of the former marital home, Grayhurst shouted an obscenity at the presiding magistrate.
- When deputies attempted to return Grayhurst to the courtroom, he resisted and kicked a deputy sheriff, causing serious injury; the Family Court found Grayhurst in contempt.
- The State charged Grayhurst with multiple offenses arising from the correspondence and the courtroom incident, including violations of no-contact orders, stalking, extortion/blackmail, threats, assault on a uniformed officer, and obstructing a police officer.
- A Superior Court jury convicted Grayhurst on twenty-five counts.

## Issues

1. Whether the Double Jeopardy Clauses of the United States and Rhode Island Constitutions barred criminal prosecution for assault and related offenses after a Family Court contempt adjudication arising from the same courtroom incident.
2. Whether multiple counts based on repeated no-contact order violations and threatening communications constituted impermissible multiple punishments for the same offense.
3. Whether the trial court committed reversible error in challenged evidentiary rulings or whether the evidence was insufficient to support certain convictions.

## Decision

- The Supreme Court of Rhode Island affirmed the Superior Court judgment and upheld the convictions.
- The court held that the contempt adjudication and the later criminal charges were not the same offense for double jeopardy purposes because they required different elements and addressed different interests.
- The court rejected the claim that multiple counts for repeated violations and threats were multiplicitous, concluding the counts reflected separate prosecutable acts under the relevant statutes.
- The court found no reversible error in the evidentiary rulings and concluded the evidence was sufficient to support the jury’s verdicts.

## Legal Principles

- Double jeopardy bars (1) a second prosecution after acquittal, (2) a second prosecution after conviction, and (3) multiple punishments for the same offense.
- Whether two proceedings involve the “same offense” turns on a comparison of the elements of the offenses, not merely whether they arise from the same factual episode.
- A contempt sanction imposed to vindicate a court’s authority does not automatically preclude subsequent criminal prosecution for distinct statutory crimes arising from related conduct when the offenses contain different elements.
- Absent clear legislative direction to treat repeated acts as a single unit of prosecution, separate violations (e.g., distinct mailings, threats, or order violations) may be charged and punished as separate offenses without violating double jeopardy.
- On appellate review, evidentiary rulings are generally reviewed for abuse of discretion, and sufficiency claims are assessed by viewing the evidence in the light most favorable to the prosecution.

## Conclusion

The court affirmed Grayhurst’s twenty-five convictions, holding that a prior contempt adjudication did not bar later prosecution for assault and related crimes arising from the same incident, and that charging separate counts for repeated no-contact order violations and threatening communications did not constitute multiple punishments for the same offense.


State v. Grayhurst, 852 A.2d 491 (R.I. 2004)