Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of four counts of first-degree sexual assault. The trial justice sentenced Defendant to four concurrent sentences of twenty years incarceration, ten years to serve, ten years suspended with probation. Defendant subsequently filed a motion to reduce his sentence, which the trial justice denied. Because the appeal was not timely filed, Defendant sought review by the Supreme Court by means of a petition for a writ of certiorari. The Court granted the petition and affirmed the decision of the superior court, holding that Defendant did not establish that the trial justice abused his discretion when he denied the motion to reduce Defendant's sentence, as the sentence was neither beyond the power of the sentencing justice to impose, nor was it patently unjustified. View "State v. Lynch" on Justia Law

Defendant pleaded guilty to manslaughter in 1994 and received a sentence of thirty years in prison with twenty years suspended, along with twenty years probation. In 2011, the superior court adjudged Defendant to be in violation of his probation and executed seven years of his previously suspended sentence. Defendant appealed, contending that the evidence presented at the probation-violation hearing was insufficient to support the hearing justice's finding that Defendant violated the terms of his probation. The Supreme Court affirmed, concluding, as did the hearing justice, that the evidence adduced at the hearing was sufficient to support a finding that Defendant had violated the terms of his probation. View "State v. Lamoureux" on Justia Law

After a jury trial, Defendant was found guilty of two counts of second-degree child molestation. Defendant filed a motion for a new trial founded on a claim that he was deprived of pretrial access to certain relevant hospital records and police reports. The trial justice denied the motion after finding that none of the hospital records needed to have been disclosed to trial counsel and that the police reports were not discoverable. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not err in (1) denying Defendant's motion for a new trial; and (2) limiting Defendant's cross-examination of the complaining witness about her refusal to undergo a physical examination. View "State v. Burnham" on Justia Law

In 2003, after completing their respective deferred sentences, Defendants James Briggs and Anna Matthias unsuccessfully moved to expunge the records of their arrests and pleas. Briggs had pled nolo contendere to second-degree robbery, and Matthias had pled nolo contendere to possession of a controlled substance. After the General Assembly amended R.I. Gen. Laws 12-19-19 in 2010, Defendants filed motions to seal their records. The court denied the motions. The Supreme Court affirmed, holding (1) the plain language of section 12-19-19, as amended, does not demonstrate a legislative intent by necessary implication that the General Assembly intended the statute to apply to deferred sentences entered into before the 2010 amendments; and (2) the addition of subsection (c) to section 12-19-19 was a substantive amendment and thus not entitled to retroactive application. View "State v. Briggs" on Justia Law

Defendant was charged by information with threatening a public official with bodily harm as a result of the lawful performance of his official duties. The superior court dismissed the information for lack of probable cause, finding that, based on the contents of the information package, the state would not be able to prove beyond a reasonable doubt that Defendant's statements constituted a threat of bodily harm to a public official in the performance of his public duties. The Supreme Court affirmed, holding that there was no evidence in the record of probable cause to support the charge, and accordingly, the motion justice did not err in dismissing the information. View "State v. Baillargeron" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and three firearms charges. The Supreme Court affirmed Defendant's convictions on all counts. Defendant subsequently filed an application for postconviction relief, alleging ineffective assistance of counsel. The superior court denied Defendant's application. The Supreme Court affirmed, holding that the trial court did not err in concluding (1) trial counsel did not have an actual conflict of interest during Defendant's representation that adversely affected the lawyers' performance; and (2) Defendant's attorneys did not render ineffective assistance in choosing not to pursue a motion to suppress evidence or to mount a third-party perpetrator defense. View "Rivera v. State" on Justia Law

After a jury trial, Defendant was sentenced to life imprisonment for the first-degree murder of his mother. Defendant subsequently filed an application for postconviction relief. The superior court appointed counsel to represent Defendant in connection with his application, but counsel determined that the issues raised in the application were frivolous and without merit and moved to withdraw as attorney of record. After a hearing and a finding that Defendant's arguments were meritless, the hearing justice granted the motion. The hearing justice then denied and dismissed Defendant's application. The Supreme Court affirmed, holding that the hearing justice did not err in (1) granting counsel's motion to withdraw, as all of the procedural requirements of Shatney v. State were followed; and (2) denying Defendant's application after giving Defendant ample opportunity to respond to the proposed dismissal of his application. View "Perez v. State" on Justia Law

Defendant entered pleas of nolo contendere to three counts of second-degree child molestation, and the hearing justice accepted Defendant's plea. Five months later, Defendant filed an application for postconviction relief, claiming that his conviction should be vacated because his plea was involuntary and because he had been denied his right to the effective assistance of counsel. The superior court dismissed Defendant's application. The Supreme Court affirmed, holding (1) Defendant voluntarily pleaded to the charges; (2) Defendant's attorney did not render ineffective assistance in pressuring him to plead to the charges or in failing to advise Defendant to inform the court that he had ingested prescription medication during the plea hearing; and (3) the hearing justice did not err in failing to draw an adverse inference against the state based on its failure to call upon Defendant's plea attorney to testify at the postconviction-relief hearing. View "Jolly v. Wall" on Justia Law

Defendant entered an Alford plea to two counts of second-degree child molestation. Seventeen years later, Defendant filed an application for postconviction relief, arguing that there was not sufficient evidence for the trial justice to support a conclusion that Defendant understood both the nature of the charges and the consequence of the plea, and thus, the plea was not made voluntarily and intelligently. The superior court denied the application. The Supreme Court affirmed, holding that there was no basis to vacate Defendant's plea, as Defendant's plea was voluntary, intelligent, and knowing, and Defendant was well aware of the nature of the charges against him at the time he pleaded to them. View "Camacho v. State" on Justia Law

In 1992, Defendant pleaded nolo contendere several charges, including first- and second-degree child molestation. Defendant was sentenced to thirty years on each of the molestation counts, with fifteen years to serve, fifteen years suspended, with probation. Defendant was later convicted of residential burglary and adjudicated a probation violator in 2004. After a probation-revocation hearing, the superior court stayed the execution of ten years of Defendant's previously suspended sentence. In 2009, Defendant admitted to a probation violation. In 2010, Defendant filed a motion to correct the 2004 sentence, arguing that the trial justice was without authority to impose a stayed sentence. The trial court granted in part Defendant's motion and vacated the 2004 sentence. The trial justice then resentenced Defendant. Defendant appealed, arguing that the 2004 was no longer a viable sentence, such that Defendant was improperly adjudged to be a probation violator in 2009, and that the trial justice impermissibly resentenced him. The Supreme Court affirmed, holding (1) the trial justice's error in staying the execution of the ten years remaining on the previously suspended sentence did not vitiate that portion of the sentence that the original sentencing justice had imposed; and (2) the trial justice correctly resentenced Defendant. View "State v. Roberts" on Justia Law