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State v. Quattrocchi



Type of Case:

Rhode Island

Location (State or Country): 


Civil or Criminal: 

Other victims

Form of Corroboration: 


State v. Quattrocchi (1994) was the first criminal case in Rhode Island involving recovered memory. Charges were brought based upon the testimony of "Gina", who recovered memories of abuse by Quattrocchi while she was receiving treatment at Butler Hospital, having been admitted for severe depression and suicidality. The state presented evidence from two other girls who reported sexual assaults by Quattrocchi: one was his own goddaughter, who the defendant cornered naked in a shower when she was seven years old (in 1977). She told her parents about it when she was a sophomore in college. The other incident occurred four years later (in 1981) and resulted in a contemporaneous report to the police. The events at issue in this criminal case cover the same years as those incidents. [In Catch-22 reasoning, the Rhode Island Supreme court subsequently ruled that such evidence was “too prejudicial” and the defendant would have to be retried without such evidence. Without such evidence, many states considered this kind of testimony too unreliable—in absence of the kind of corroboration that the Rhode Island court now prohibits.]

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