Justia Rhode Island Supreme Court Opinion Summaries

After a trial at which he represented himself, Defendant was convicted of kidnapping, domestic felony assaults, intimidation of a witness, and violation of a no-contact order. The Supreme Court affirmed the convictions. Defendant subsequently filed several motions, which the superior court treated as a subsequent application for postconviction relief and then denied. In the motions, Defendant argued, inter alia, that the prosecutor erred in failing to produce certain victim-impact statements in response to his discovery requests. The Supreme Court affirmed, holding (1) even if the claims underlying this postconviction relief application were not barred by res judicata, they were meritless; (2) even if the State had disclosed the victim-impact statements to Defendant before trial, Defendant failed to demonstrate that the result of his trial would have been different, and therefore, Defendant's claim that the State violated Brady v. Maryland failed; (3) Defendant was not prejudiced by the State's failure to disclose the victim-impact statements under R.I. R. Evid. 16; and (4) Defendant was not entitled to postconviction relief based on newly discovered evidence. View "State v. Thornton" on Justia Law

After a jury trial, Defendant was convicted of simple domestic assault. The Supreme Court affirmed the judgment of conviction, holding that the trial justice (1) did not err in giving a jury instruction with respect to intent; (2) did not err in limiting Defendant's constitutional right to cross-examination of the complainant; (3) did not err in allowing a witness to express his opinion that Defendant was the aggressor because even if the testimony consisted of impermissible vouching, the admission of the testimony did not constitute prejudicial error; and (4) Defendant failed to establish any prejudice arising from the complainant's email having been read into the record rather than having been marked as an exhibit or otherwise provided to Defendant. View "State v. Kausel" on Justia Law

While on probation, Defendant fled from two police officers. After Defendant was arrested, a firearm was discovered on the floor of his car. A trial justice later found Defendant to be a violator of the terms and conditions of his probation. In addition to the probation-violation proceeding, the State charged Defendant with recklessly operating a motor vehicle, carrying a revolver without a license, and possession of a firearm after having been convicted of a crime of violence. During the course of the violation hearing, the State requested, in a motion in limine, that the trial justice interpret the Firearms Act in such a manner that a weapon need not be capable of expelling a projectile to fit within the definitions of "firearm" or "pistol." The trial justice denied the motion. The Supreme Court affirmed, holding (1) the trial justice did not err in finding that Defendant violated the terms of his probation; and (2) the trial justice correctly denied the State's motion in limine. View "State v. Hazard" on Justia Law

After a jury trial, Defendant was convicted of first degree child abuse for inflicting serious bodily injury on his infant son. Defendant was sentenced to twenty years incarceration. The Supreme Court affirmed the conviction, holding (1) the trial justice correctly denied Defendant's challenge to the constitutionality of the child abuse statute; (2) the trial justice did not err when he admitted a statement that Defendant wrote at the police station because Defendant knowingly and voluntarily waived his Miranda rights before providing the statement; and (3) the trial justice did not err in denying Defendant's motion for a judgment of acquittal and his motion for a new trial. View "State v. Allen" on Justia Law

After a jury trial, Defendant was convicted of one count of possession of marijuana and two counts of possession of cocaine with the intent to deliver while armed with or having available a firearm. Defendant appealed, arguing, among other things, that the trial justice erred in permitting the State to impeach his credibility with an allegation of previous criminal conduct and with information that was false and prejudicial. The Supreme Court vacated the judgment of conviction, holding (1) the trial court's questions concerning the nature of the offense with which Defendant was previously charged were improper and inappropriate for impeachment purposes because not only did these questions place factually incorrect information before the jury, but they impermissibly introduced false evidence of Defendant's previous criminal conduct; and (2) the error was not harmless. View "State v. Price" on Justia Law

After a jury trial, Defendant was convicted of first-degree child molestation. Defendant appealed, contending (1) the trial justice erred in denying his motion to suppress a statement he made to the police as the fruit of an unlawful arrest, and (2) the trial justice erred in admitting the statement without first redacting certain portions. The Supreme Court affirmed, holding (1) because Defendant was validly arrested, and because the trial justice did not err in concluding that Defendant knowingly, voluntarily, and intelligently waived his Miranda rights, the court properly denied Defendant's suppression motion; and (2) the trial justice did not err in refusing to redact Defendant's statement to police. View "State v. Morin" on Justia Law

After a jury trial, Defendant was convicted of first-degree sexual assault. Defendant appealed, contending that the trial justice erred in (1) refusing to give Defendant's requested jury instructions on the defense of consent, (2) admitting certain testimony under the excited-utterance exception to the hearsay rule, and (3) denying his motion to dismiss the indictment due to irregularities in the grand jury proceedings. The Supreme Court affirmed, holding that the trial justice (1) did not err in refusing to instruct the jury on a consent defense that was unsupported by any of the testimony given at trial; (2) did not abuse its discretion in admitting the testimony under the excited-utterance exception to the hearsay rule; and (3) did not err in denying Defendant's request to dismiss the indictment, as any error that may have occurred during the grand jury proceeding was harmless. View "State v. Martin" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, three counts of using a firearm while committing a crime of violence, burglary, and two counts of assault with a dangerous weapon. Defendant appealed, arguing that the trial justice erred in refusing to admit evidence about the alleged drug possession and intoxication of certain of the state's witnesses and in allowing into evidence prejudicial information about Defendant's parole status. The Supreme Court affirmed, holding that the trial justice (1) did not abuse his discretion in limiting the cross-examination of the witnesses' alleged drug use and possession; (2) correctly ruled that evidence of the witnesses' possible intoxication was inadmissible because it did not rise to the level of intoxication; and (3) did not abuse his discretion in permitting the references to Defendant's parole status. View "State v. Bishop" on Justia Law

After a trial, Defendant was convicted of felony assault for arming himself with a baseball bat and allegedly defending a female friend whom he thought was being threatened. Defendant subsequently filed an application for postconviction relief, alleging his trial counsel was ineffective because his attorney gave him incorrect legal advice, which robbed him of the opportunity to consider and accept a plea offer. The Supreme Court affirmed, holding (1) the trial justice did not err in determining that trial counsel provided competent advocacy to Defendant; and (2) Defendant failed to prove that he was prejudiced in any way by trial counsel's performance. View "Bell v. State" on Justia Law

Fifteen-year-old Jennifer Rivera was an eyewitness to the murder of Hector Feliciano and was under subpoena to testify in a murder trial. Before the trial, Jennifer was shot several times at close range in order to prevent her from testifying against Defendant, who was charged with and awaiting trial on the Feliciano murder. During the ensuing police investigation, three individuals, including Defendant, were found to have planned and participated in Jennifer's murder. Defendant was subsequently convicted of first-degree murder, conspiracy, obstruction of justice, and numerous firearms counts. The Supreme Court affirmed, holding (1) the trial justice did not abuse his discretion in admitting various items of evidence, including evidence that Defendant committed the Feliciano murder; (2) the trial justice did not err in his instructions to the jury on evaluating witness credibility; (3) the trial justice properly did rejected Defendant's Batson challenge to the State's use of a peremptory challenge; (4) the State did not engage in improper vouching; and (5) the trial justice did not err in denying Defendant's motion for a new trial. View "State v. Pona" on Justia Law