Justia Rhode Island Supreme Court Opinion Summaries

In 1999, Defendant entered a plea of nolo contendere to first-degree robbery. While he was on parole from that sentence, Defendant was charged with and subsequently pleaded nolo contendere to two counts of second-degree child molestation. In 2006, Defendant filed an application for postconviction relief, alleging that the attorney who had represented him in the child molestation case had rendered ineffective assistance because he had erroneously advised Defendant. The trial justice denied the application. The Supreme Court affirmed, holding (1) the trial justice did not err in determining that Defendant had failed to demonstrate he had received the advice he claimed was constitutionally deficient; and (2) Defendant failed to demonstrate that he suffered any prejudice from the alleged erroneous advice. View "Perkins v. State" on Justia Law

Defendant was convicted of nine felony counts, including second-degree murder and related firearms offenses. The trial court imposed a mandatory consecutive life sentence for use of a firearm in the commission of a homicide. After unsuccessfully filing two applications for postconviction relief, Defendant filed this third petition for postconviction relief, which the district court also denied. The Supreme Court affirmed, holding (1) Defendant's mandatory consecutive life sentence for discharging a firearm while committing a crime of violence resulting in death did not constitute cruel and unusual punishment; (2) Defendant's conviction and sentence for second-degree murder and discharging a firearm while committing a crime of violence did not violate the constitutional proscription against double jeopardy; and (3) defense counsel did not provide ineffective assistance. View "Linde v. State" on Justia Law

After a jury trial, Defendant was convicted of breaking and entering and felony assault with a dangerous weapon. The Supreme Court affirmed, holding that the trial justice (1) did not err in denying Defendant's motion for a new trial because the the jury's verdict was supported by the evidence; (2) did not abuse his discretion by deciding not to permit defense counsel to question prospective jurors about eyewitness testimony during voir dire; and (3) did not err in denying Defendant's motion for a judgment of acquittal on the charge of assault with a dangerous weapon because the evidence was sufficient to prove that the intruder's hands, by choking the complainant, were used as a dangerous weapon as statutorily required. View "State v. Lopez" on Justia Law

After a jury trial, Defendant was convicted of seven criminal offenses, including conspiracy to commit murder. The trial justice sentenced Defendant to consecutive life sentences plus twenty non-parolable years to run consecutively to the life sentences. The Supreme Court affirmed, holding (1) Defendant waived his arguments that the trial justice erred when he admitted certain evidence; and (2) the trial justice did not err by failing to dismiss the offense of discharging a firearm while in the commission of a crime of violence because, contrary to Defendant's assertions, the charge did not merge for double-jeopardy purposes with the offense of assault with a dangerous weapon with intent to murder. View "State v. Young" on Justia Law

After a jury trial, Defendant was convicted of multiple counts of felony assault and of using a firearm while committing a crime of violence and one count of carrying a pistol or revolver without a license. The Supreme Court affirmed on appeal, holding (1) the trial justice did not err in admitting a statement the victim made to police shortly after he was shot because the statement was relevant and the probative value of the evidence was not substantially outweighed by the danger of unfair prejudice; (2) the trial court did not deprive Defendant of his right to present a full defense, as Defendant was accorded leeway in presenting a third-party-perpetrator defense; and (3) the trial justice did not err in denying Defendant's motion for a new trial. View "State v. Covington" on Justia Law

After a bench trial, Defendant was convicted of criminal counts, including larceny, assault with a dangerous weapon, and violation of a protective order. Defendant appealed, arguing, among other things, that the State failed to comply with the Interstate Agreement on Detainers Act (IADA), and therefore, the trial court erred when it did not dismiss the charges against him. The Supreme Court affirmed the convictions, holding (1) the trial court did not err in denying Defendant's motion to dismiss, as Defendant forfeited his IADA argument for failing to raise it before the deadline expired; and (2) Defendant's convictions for both larceny and assault with a dangerous weapon did not violate the Double Jeopardy Clauses of the state and federal constitutions. View "State v. Oliver " on Justia Law

Defendant pled nolo contendere to assault with a dangerous weapon. The trial justice sentenced Defendant to twenty years incarceration, with ten years to serve and ten years suspended with probation. One year after Defendant unsuccessfully moved for a sentence reduction under R.I. R. Crim. P. 35, Defendant filed a motion requesting the trial justice assign for a hearing the previously filed Rule 35 motion. After a hearing, the trial justice granted the motion and amended Defendant's sentence to twenty years, nine years to serve and eleven years suspended with probation. The Supreme Court quashed the superior court's judgment modifying Defendant's term to serve, holding that Defendant's motion to reduce sentence/assign pursuant to Rule 35 was not properly before the trial court because, notwithstanding the language contained within the text of that motion, the filing was an untimely filed new motion, and therefore, the trial justice erred in granting the motion. View "State v. Keenan" on Justia Law

After a jury trial, Defendant was convicted of first degree sexual assault. The Supreme Court affirmed the conviction, holding that the trial court did not err in (1) declining to dismiss the indictment based upon a partially inaudible and incomplete grand jury record, as an unintentional failure to record or reproduce the grand jury proceedings does not affect the validity of the prosecution; (2) denying Defendant's motion to pass the case based upon Sup. Ct. R. Crim. P. 16 violations by the state, where a violation of Rule 16 occurred in this case, but the nondisclosures were not deliberate on the part of the prosecutor; and (3) admitting the testimony of an expert in the field of sexual abuse, as the testimony did not constitute impermissible vouching or bolstering of other fact witnesses. View "State v. Huffman" on Justia Law

Defendant was indicted for several sex-related crimes. Defendant opted to exercise his constitutional right to represent himself. After the jury was sworn, Defendant expressed his desire to absent himself from the trial in the event a plea agreement was not reached. The trial continued in Defendant's absence. The jury subsequently found Defendant guilty of three counts of first-degree child molestation sexual assault and two counts of first-degree sexual assault. Defendant appealed, contending, among other things, that the trial justice was constitutionally required to appoint counsel to represent him when he absented himself from trial. The Supreme Court affirmed, holding (1) Defendant validly waived his right to counsel; (2) the trial justice did not abuse his discretion in denying Defendant's post-waiver request for counsel; (3) the trial justice was not constitutionally required to appoint counsel to represent Defendant after he chose to proceed pro se and then absented himself from trial; and (4) Sup. Ct. R. Crim. P. 43 did not present any bar to Defendant's trial continuing, even after he elected not to be present. View "State v. Eddy" on Justia Law

Plaintiff was an inmate serving a life sentence incarcerated at the Adult Correction Institutions (ACI). Plaintiff filed an amended complaint naming as defendants employees of the ACI and Department of Corrections (DOC), alleging that Defendants violated his right to privacy by monitoring him via video camera while he was in his prison cell and that Defendants regularly harassed him. The trial justice dismissed the complaint. The Supreme Court affirmed. Meanwhile, Plaintiff filed another complaint against thirteen employees of the DOC. Along with the complaint, Plaintiff filed a motion to proceed in forma pauperis. The trial court denied Plaintiff's motion and entered an administrative order restricting Plaintiff from filing any further pro se actions in superior court. The Supreme Court vacated the orders restricting Plaintiff from filing any pro se actions, holding that the order did not comport with Supreme Court precedent and impermissibly infringed upon Plaintiff's right of access to the courts. View "Laurence v. R.I. Dep't of Corr." on Justia Law