Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of three counts of first-degree child molestation and three counts of second-degree child molestation. Defendant appealed, arguing that the trial justice's denial of his motion for a new trial was clearly erroneous because the jury's verdict was against the weight of the evidence and failed to do substantial justice. Specifically, Defendant argued that the testimony of the complaining witness lacked credibility. The Supreme Court affirmed, holding (1) the trial justice performed an exhaustive review of the testimony presented at trial and thoughtfully evaluated the evidence and credibility of the witnesses; and (2) the trial justice's findings and conclusions in denying Defendant's motion for a new trial were well within his discretion. View "State v. LaPierre" on Justia Law

Defendant was convicted of possession of cocaine with the intent to deliver and possession of cocaine in an amount between one ounce and one kilogram. In his appeal, Defendant challenged the denial of his motion to suppress evidence seized from his home, arguing that the affidavit underlying the warrant did not provide the requisite probable cause to support a search of his residence. The Supreme Court affirmed, holding (1) the totality of the circumstances presented within the affidavit was sufficient to enable the magistrate to reasonably infer that illegal contraband would be found in Defendant's residence; and (2) the trial justice did not err in determining that the confidential informant's tip was properly corroborated or that this corroborated tip, combined with Defendant's recent sale of cocaine in a controlled buy, satisfied the probable cause requirement to support the warrant authorizing the search of Defendant's residence. View "State v. Cosme" on Justia Law

Plaintiffs in this case included fifteen minor children and their parents who participated in the family court's truancy court diversion calendar program. The diversion program allowed family court magistrates to conduct court sessions at public schools where truancy had become an issue. Plaintiffs brought an action against the judicial officials who were sitting in the truancy court, family court administrators, and five municipalities. Plaintiffs requested that the superior court declare the previous procedures in the truancy court to be unconstitutional and enjoin the family court from enforcing the prior procedures. The superior court denied Defendants' motions to dismiss under Sup. Ct. R. Civ. P. 12(b)(1). The Supreme Court quashed the superior court's order denying Defendants' motions to dismiss, holding that Plaintiffs' claims were moot, as (1) Plaintiffs' constitutional challenges were obviated by an administrative order that reformed the truancy program and by existing law; and (2) there were no ongoing truancy petitions that continued to be affected by the earlier court procedures. View "Boyer v. Bedrosian" on Justia Law

Defendant was convicted of violating his probation. The superior court executed thirty months of Defendant's previously imposed suspended sentence. The Supreme Court affirmed the judgment of the superior court, holding (1) Defendant waived his argument for appeal that the hearing justice properly refused to admit a letter written and sent to him by the State's complaining witness; (2) the hearing justice did not abuse its discretion in limiting testimony concerning past arguments between Defendant and the complaining witness about the complaining witness's drug use and whether the complaining witness had bought him drugs when he was in a drug-treatment program; and (3) the hearing justice did not act arbitrarily and capriciously in finding a violation. View "State v. Ford" on Justia Law

Defendant was convicted of first-degree murder. The Supreme Court affirmed the conviction. Nearly a decade later, Defendant filed a pro se application for postconviction relief, claiming six allegations of error. The trial justice dismissed five out of the six allegations raised in the application as barred by principles of res judicata. A court-appointed attorney subsequently made an independent evaluation to determine whether Defendant's remaining claim of ineffective assistance of counsel had merit. Appointed counsel concluded that none of Defendant's arguments had merit. A trial justice then informed Defendant that his only allegation of ineffective assistance of counsel could proceed to a hearing and that he had no right to be represented by an attorney. After a hearing in which Defendant proceeded pro se, the trial justice granted the State's motion to dismiss. The Supreme Court vacated the judgment and remanded, holding (1) the trial justice erred in summarily dismissing five of Defendant's claims without first providing him with appointed counsel and a meaningful opportunity to respond; and (2) the trial justice's appointment of an "objective attorney" to make an "independent evaluation" of the merits of Defendant's claim of ineffective assistance of counsel violated R.I. Gen. Laws 10-9.1.5. View "Campbell v. State" on Justia Law

Defendant was convicted of one count of first degree child molestation and two counts of second degree of child molestation. Defendant was the great-uncle of the complaining witness. On appeal, Defendant argued that the trial justice erred in failing to grant his motion for a new trial due to the lack of credibility of the witnesses and the inconsistent evidence concerning the alleged molestations. The Supreme Court affirmed, holding that the trial justice did not clearly err or misconceive evidence in denying Defendant's motion for a new trial, as the trial justice completed each of the analytical steps called for when a trial justice is presented with a motion for a new trial. View "State v. Gonzalez" on Justia Law

Defendant was convicted of aiding and abetting murder and conspiracy to commit robbery. The Supreme Court affirmed on direct appeal. Defendant subsequently filed an application for postconviction relief, setting forth five allegations of error, including the allegation that counsel's failure to seek dismissal of the indictment on speedy trial grounds amounted to ineffective assistance of counsel. The trial justice denied the application. The Supreme Court affirmed, holding that the trial justice's denial of Defendant's allegation of ineffective assistance of counsel was correct, as Defendant's speedy-trial contention ultimately would have proven unsuccessful, and Defendant could not show that the result of the proceeding against him would have been different. View "Bido v. State" on Justia Law

Defendant appealed from a superior court judgment of conviction declaring him to be in violation of his probation and executing four years of his previously imposed suspended sentence. On appeal, Defendant argued there was no reliable evidence for the hearing justice to find he violated the terms of his probation and therefore, the hearing justice acted arbitrarily and capriciously in finding a violation. The Supreme Court affirmed the judgment of the superior court, holding that the hearing justice was well within her discretion in concluding that Defendant violated the terms of his probation by not keeping the peace or being of good behavior. View "State v. Bellem " on Justia Law

Appellant was convicted of first-degree murder, assault with intent to murder, and assault with a dangerous weapon. Appellant subsequently filed an application for postconviction relief, which the superior court denied. On appeal, Appellant contended (1) his postconviction relief application should have been granted based on a violation of his right to due process, and (2) he was prejudiced by the ineffective assistance of his trial counsel because his counsel failed to object to what Appellant maintained was improper witness vouching and because his trial counsel failed to object to a first-degree murder instruction that the trial justice imparted to the jury. The Supreme Court affirmed the denial of Appellant's application for postconviction relief, holding (1) Appellant's postconviction challenge was barred by the doctrine of res judicata, and Appellant's conviction was proper; and (2) trial counsel did not render ineffective assistance. View "Jaiman v. State" on Justia Law

Defendant appealed from a judgment of conviction on two counts of assault with a dangerous weapon and one count of discharging a firearm while committing a crime of violence. Defendant argued on appeal that the trial justice erred when he (1) admitted into evidence a prejudicial hearsay statement as an excited utterance; and (2) admitted a statement as lay-witness opinion testimony. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not abuse his discretion when he (1) admitted into evidence the hearsay statement as an excited utterance; and (2) allowed a lay witness to testify as to what he perceived at the time of the alleged shooting. View "State v. Tep" on Justia Law