Justia Rhode Island Supreme Court Opinion Summaries

Following a jury trial, Defendant Gilbert Delestre was found guilty of second-degree murder and of conspiracy to commit the offense of murder. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not err in (1) instructing the jury concerning the concept of aiding and abetting, as the instruction considered in its entirety did not relieve the State of its burden and did not violate Defendant's due process rights; and (2) declining to give a unanimity instruction to the jury with respect to the murder charge, as the jury was not required to unanimously agree as to whether Defendant was guilty of second-degree murder as a principal, as an aider or abettor, or as a coconspirator. View "State v. Delestre" on Justia Law

Defendant Giulio Lancellotta pled nolo contendere to second-degree robbery and was sentenced to twelve years in prison, which sentence was suspended, and twelve years probation. A magistrate later found that Defendant had violated his probation and sentenced him to serve seven years of his twelve-year suspended sentence. The Supreme Court affirmed, holding (1) the magistrate did not abuse his discretion when he denied Defendant's motion for new counsel; (2) the magistrate did not act arbitrarily or capriciously when he found that the evidence presented at the probation-violation hearing was sufficient to demonstrate that Defendant had violated his probation; and (3) the magistrate acted within his discretion in imposing the sentence. View "State v. Lancellotta" on Justia Law

Defendant Adrian Shepard pled nolo contendere to conspiracy to commit a felony, for which he was sentenced to ten years at the adult correctional institutions, consisting of two years to serve and eight years suspended, with probation. The superior court subsequently declared Shepard to be in violation of the terms of his probation and revoked three years of Shepard's suspended sentence. The Supreme Court affirmed the judgment of the superior court, holding (1) the hearing justice did not act arbitrarily or capriciously in finding that the State presented sufficient evidence to meet the burden of reasonable satisfaction to find that Shepard violated his probation; and (2) the revocation of three years of Shepard's suspended sentence was a sustainable exercise of the hearing justice's broad discretion. View "State v. Shepard" on Justia Law

After a jury trial, Defendant was convicted of domestic first-degree sexual assault and domestic assault with intent to commit sexual assault. The Supreme Court affirmed, holding (1) the trial justice did not abuse her discretion by refusing to pass the case after the complainant testified that the police issued to her a no-contact order against Defendant where the testimony was not sufficiently prejudicial as to prevent the jury from calmly and dispassionately considering the evidence and the cautionary instructions provided by the trial justice alleviated any prejudicial impact of the testimony; and (2) the trial justice did not abuse her discretion by denying a second motion to pass the case when a police officer, while testifying, improperly bolstered the complainant's credibility where the improper bolstering was not sufficiently prejudicial to Defendant. View "State v. Rushlow" on Justia Law

After a jury trial, Defendant Miguel Navarro was convicted of first-degree child molestation sexual assault. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not abuse her discretion in (1) denying Defendant's motion for a sixty-day continuance prior to trial, after considering the totality of the circumstances surrounding the motion; (2) denying Defendant's motions for judgment of acquittal, where the evidence was sufficient to withstand the motion; and (3) denying Defendant's motion for a new trial, where the trial justice provided sufficient reasoning in support of her ruling and the evidence was sufficient to withstand the motion. View "State v. Navarro" on Justia Law

After a jury trial, Defendant Carlos Jimenez was convicted on two counts of first-degree sexual assault after being accused by his sister-in-law of sexually assaulting her while she was too intoxicated to resist. The Supreme Court affirmed, holding (1) the trial justice correctly denied Defendant's motion to suppress a statement he gave to an officer while at his mother-in-law's apartment because he was not in custody at the time; (2) the trial justice did not err in admitting statements Defendant made while in custody at the police statement because Defendant voluntarily, knowingly, and intelligently waived his Miranda rights in making the statement; and (3) the trial justice did not clearly err in denying Defendant's motion for a new trial. View "State v. Jimenez" on Justia Law

After a jury trial, Defendant Raquel Figuereo was found guilty of shoplifting. As her sole argument on appeal, Defendant contended that the trial justice erred in declining to instruct the jury that eyewitness certainty is not a reliable indicator of eyewitness accuracy. The Supreme Court affirmed the judgment of the superior court, holding (1) because the instruction that on appeal Defendant contended should have been given differed in wording and in meaning from the language which Defendant at trial requested the trial justice to include in his instructions, Defendant waived her right to argue to the Court in favor of her proposed instruction; and (2) even if Defendant had properly raised her argument before the Court, her appeal would still be unavailing because the jury was, in essence, instructed in accordance with Defendant's expressed wishes, although not in the precise words that she requested. View "State v. Figuereo" on Justia Law

Defendant Roy Diefenderfer was convicted of first-degree robbery, conspiracy to commit robbery, kidnapping, and assault of a person over sixty years of age. Defendant thereafter moved for a reduced sentence, arguing that his sentence be reduced because of, inter alia, his good behavior at the adult correctional institutions and the extreme hardship his family endured during his incarceration. The hearing justice - a different justice from the one who originally sentenced Defendant - denied the motion. The Supreme Court vacated the order of the superior court, holding that the hearing justice applied an incorrect standard in denying Defendant's sentence-reduction motion, as, specifically, the justice erroneously applied the appellate standard of review. View "State v. Diefenderfer" on Justia Law

A jury convicted Defendant Ronald Barkmeyer of first-degree child molestation. The trial justice sentenced Defendant to fifty years incarceration, with thirty years to serve and the remaining twenty years suspended, with probation. Thereafter, Defendant moved for a reduced sentence. The superior court denied the motion. The Supreme Court affirmed the order of the superior court, holding that the trial justice (1) did not abuse his discretion in failing to afford much, if any, weight to defendant's prison behavior or rehabilitative efforts, and (2) properly exercised his discretion in not bestowing upon Defendant the leniency he requested and confirming Defendant's sentence. View "State v. Barkmeyer" on Justia Law

When he was fifteen years old, Craig Price admitted committing four brutal murders. Price was committed to the custody of a training school, and the family court directed the school to provide intensive psychiatric treatment for Price. Later, Craig Price was convicted of criminal contempt for refusing to cooperate in psychiatric treatment, after previously having been adjudicated to be in civil contempt for the same offense. Price was sentenced by the family court to twenty-five years at the adult correctional institutions, with ten years to serve and the balance suspended, with probation. The Supreme Court affirmed. Price subsequently filed an application for postconviction relief, which the family court denied. The Supreme Court affirmed, holding (1) res judicata barred the Court from considering Price's double jeopardy claim; (2) because Price's double jeopardy claim had no merit, Price's counsel was not ineffective by failing to raise it; (3) the trial justice acted within his discretion in imposing the sentence, and the sentence was not excessive; and (4) Price's claim that he was denied due process because he was declared a violator and ordered to serve a portion of the suspended sentence, which had not yet begun, was barred by res judicata. View "Price v. Wall" on Justia Law