State v. Latraverse
Supreme Court of Rhode Island
443 A.2d 890 (1982)
Undercover detective Salvatore Lombardi bought four stolen cars from Paul Latraverse (defendant), who was arrested and released on bail pending a grand jury proceeding at which Lombardi was to testify. Late one night, Lombardi heard a loud-mufflered car stop near his home bearing a license plate from Latraverse's dealership; when police backup approached, the car made a U-turn and fled, and officers pursued and searched it, finding gasoline, a rag, matches, a baseball bat, a tool for prying open car doors, and a threatening note addressed to Lombardi. Latraverse was charged with attempting to dissuade a police officer from testifying before a grand jury; he moved for acquittal, arguing he had abandoned his plan, but the trial judge ruled the abandonment defense unavailable and convicted him.
Whether a defendant may only be convicted for attempting a crime if he took actions constituting a substantial step toward committing it.