Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of simple domestic assault. Defendant appealed, contending, inter alia, that the trial justice erred when she allowed a patrolman to testify about Defendant's admission that he owned handcuffs. Defendant alleged (1) the statement was given while he was in police custody and before the police read him his Miranda rights; and (2) the police obtained the admission during an illegal search and seizure. The Supreme Court affirmed, holding (1) Defendant's freedom of movement was not restricted to the degree associated with formal arrest, and therefore, Defendant was not in police custody when he made his statement; (2) because Defendant's answer about handcuffs was not prompted by illegally seized evidence, nor was the answer induced by illegally seized evidence, the trial justice did not violate Defendant's constitutional rights by allowing the patrolman to testify regarding Defendant's admission that he owned handcuffs; and (3) the trial justice did not err in denying Defendant's motion for a new trial. View "State v. Harrison" on Justia Law

After a jury trial, Defendant was convicted of first degree child abuse for inflicting serious bodily injury on his infant daughter. Defendant appealed, asserting that his right to confrontation under the federal and state constitutions was violated when the trial justice allowed a pediatrician to testify regarding out-of-court statements made by a colleague of hers - an ophthalmologist who performed a retinal exam on the injured infant. The Supreme Court affirmed, holding (1) Defendant failed adequately to raise his constitutional argument at trial; and (2) the narrow exception to the "raise or waive" rule did not apply in this case. View "State v. Moten" on Justia Law

Defendant was convicted of one count of first-degree child molestation sexual assault and four counts of second-degree child molestation assault. Defendant subsequently filed an application for postconviction relief, alleging, inter alia, that his counsel committed prejudicial error when he provided Defendant's confidential psychiatric records to the state without Defendant's knowledge or consent. The superior court denied the application. The Supreme Court affirmed, holding (1) the disclosure and use of the psychiatric records was not enough to prejudice Defendant to the extent of undermining confidence in the outcome of the case; and (2) the postconviction relief justice did not err in concluding that trial counsel was not ineffective to a constitutional dimension for other alleged deficiencies. View "Hazard v. State" on Justia Law

After a jury trial, Defendant was convicted of multiple counts of first-degree sexual assault and second-degree sexual assault and one count of simple assault for his assault against three developmentally disabled women. The cumulative result of Defendant's sentences was life imprisonment followed by a consecutive term of sixteen years to serve. Defendant subsequently filed a motion to reduce his sentence, arguing that the sentence was disproportionate and excessive. The trial court denied Defendant's motion, explaining that the fact that each of the victims in this case was developmentally disabled was the driving force behind the sentence imposed. The Supreme Court affirmed, holding that the trial justice did not abuse his discretion in imposing this sentence and denying Defendant's motion to reduce. View "State v. Rivera" on Justia Law

Defendant entered a plea of nolo contendere to one felony count of possession of a controlled substance. Defendant complied with her conditions of probation. Defendant was subsequently charged with two misdemeanor offenses, both of which were dismissed. Defendant moved to have the records related to the two misdemeanor charges sealed and to have the law-enforcement-identification records related to those charges destroyed. The district court denied the motion, concluding that a nolo plea, followed by a sentence of probation, is considered a conviction for the purposes of the expungement statute. Defendant appealed, arguing that she was not convicted of a felony as defined by R.I. Gen. Laws 12-18-3. The Supreme Court quashed the decision of the district court, holding that, for purposes of the sealing statute, Defendant was not convicted of a felony, she met all the statutory requirements of the sealing statutes, and she was entitled to the benefits provided in those enactments. View "State v. Poulin" on Justia Law

After a jury trial, Defendant was convicted of one count of child enticement. Defendant subsequently filed a motion for a new trial, arguing that there was insufficient evidence to support a conviction on the count of child enticement. The trial justice denied the motion. Defendant subsequently filed a second motion for a new trial based on a claim of newly discovered evidence, which the trial justice also denied. At the conclusion of the hearing on Defendant's second motion for a new trial, the trial judge adjudged Defendant in contempt of court. The Supreme Court affirmed the judgment of conviction as well as the adjudication of contempt, holding (1) Defendant waived the opportunity to argue the insufficiency of the evidence before the Court; (2) the trial justice did not overlook or misconceive material evidence, nor was he otherwise clearly wrong in denying Defendant's second motion for a new trial; and (3) the trial justice did not err in summarily adjudicating Defendant in contempt. View "State v. Price" on Justia Law

After a jury trial, Defendant was convicted of carrying a firearm in a motor vehicle without a license. Defendant appealed, arguing that the trial justice erred (1) when he denied Defendant's motion to suppress a revolver and bullets that Defendant alleged were illegally seized, and (2) in denying Defendant's motion of acquittal. The Supreme Court affirmed, holding (1) the search that led to the seizure of the contested evidence was constitutionally valid, and therefore, the trial justice did not err in denying Defendant's motion to suppress; and (2) there was sufficient evidence to uphold Defendant's conviction, and therefore, the trial justice did not err when he denied Defendant's motion for a judgment of acquittal. View "State v. Santos" on Justia Law

Defendant was charged with two counts of felony assault. After a jury trial, Defendant was convicted of the lesser-included offense of simple assault and of a serious bodily injury felony assault. Defendant appealed, arguing that the trial justice erred by denying his motion for judgment of acquittal and his motion for a new trial. The Supreme Court affirmed the judgment of conviction, holding (1) there was sufficient evidence to support a conviction of felony assault, and therefore, the trial court did not err in denying Defendant's motion for a new trial; and (2) any analysis of the denial of Defendant's motion for judgment of acquittal was unnecessary. View "State v. Gaffney" on Justia Law

After a jury trial, Defendant was convicted of seven counts of simple assault. At the time of the alleged incidents, Defendant was a captain at the Rhode Island Adult Correctional Institutions (ACI). The charges leveled against Defendant related to his treatment of four ACI inmates. The Supreme Court affirmed the judgment of conviction, holding that the trial justice did not commit reversible error when he (1) denied Defendant's motion to sever his trial from that of his co-defendant; (2) granted the prosecution's motion to preclude the testimony of an inmate; (3) denied Defendant's motion for a new trial; (4) instructed the jury; and (5) allowed the prosecution to introduce certain photographs into evidence that were not disclosed during discovery, as the nondisclosure was inadvertent and did not prejudice Defendant. View "State v. Botas" on Justia Law

Plaintiff filed suit against the State alleging statutory claims under the Rhode Island Fair Employment Practices Act, the Rhode Island Civil Rights Act, and the Rhode Island Whistelblowers' Protection Act. The State filed a motion to dismiss and a motion for summary judgment, arguing that the claims should be barred by the doctrine of res judicata because Plaintiff had previously filed a nearly identical suit in federal court, which dismissed the action. The superior court denied the State's motions. The Supreme Court quashed the decision of the superior court and remanded, holding that the federal court judgment was entitled to preclusive effect, and Plaintiff's claims were barred by res judicata. View "Huntley v. State" on Justia Law