Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Applicant Theodore Chapdelaine was found guilty of second-degree child molestation. Defendant later filed an application for postconviction relief, alleging ineffective assistance of his trial defense counsel. The trial justice denied Applicant's application, finding his claims to be without merit. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not err in denying the motion where (1) counsel's conduct during plea negotiations was not so deficient as to constitute ineffective assistance of counsel; (2) Applicant affirmatively waived any claim of error arising out of an alleged conflict of interest; (3) counsel's strategy of excluding any mention of drug or alcohol use at the trial to protect Applicant constituted professionally reasonable judgment; and (4) counsel's representation was not ineffective because he failed to explore the use of expert testimony to establish the significance of Applicant's possible psychological issues. View "Chapdelaine v. State" on Justia Law

After a jury trial, Gerald Brown was convicted of sexual assault and child molestation. The superior court dismissed his second application for postconviction relief. The Supreme Court affirmed, holding that the hearing justice (1) properly concluded that Brown's application could be summarily decided without an evidentiary hearing after providing Brown sufficient opportunity to respond to the proposed dismissal of his application; (2) appropriately deemed Brown's claim of newly discovered evidence as waived; (3) properly dismissed Brown's claim of unlawful incarceration; and (4) correctly dismissed Brown's assertions of ineffective assistance of counsel based on prior counsels' failure to raise a statute-of-limitations defense. View "Brown v. State" on Justia Law

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

Police officers applied for and obtained a search warrant for Defendant Edward Gordon's apartment after a woman reported that Defendant had sexually assaulted her. A jury convicted Defendant of second-degree sexual assault and deadlocked on Defendant's kidnapping charge. Defendant appealed, arguing (1) the superior court magistrate had no authority issue the search warrant, and (2) retrial on the charge of kidnapping would violate his rights with respect to the double-jeopardy provisions of the state and federal Constitutions. The Supreme Court affirmed, holding (1) the magistrate had the authority to issue the search warrant, and (2) the trial justice did not abuse his discretion when he determined that the jury was genuinely deadlocked, and therefore, retrial on the charge of kidnapping did not violate double jeopardy. View "State v. Gordon" on Justia Law

Defendant Windell McRae was convicted for simple domestic assault. Defendant appealed, arguing, inter alia, that a remark by complainant that Defendant had been drinking on the day of the assault was sufficiently prejudicial as to prevent the jury from calmly and dispassionately considering the evidence. The Supreme Court affirmed the superior court, holding (1) considering the full testimonial evidence and the trial justice's specific and cautionary instruction to the jury, the trial justice did not clearly err by denying Defendant's motion to pass the case after the complainant testified about Defendant's drinking; and (2) the trial justice did not abuse his discretion in admitting, for impeachment purposes, evidence of Defendant's prior convictions. View "State v. McRae" on Justia Law

Twelve-year old Frances G. told a law enforcement officer that she threw a rock or brick against the windshield of a vehicle and carved something into the side of the vehicle. After a trial before a justice of the family court, Frances was adjudicated to be wayward. The Supreme Court affirmed, holding (1) the trial justice was not clearly wrong when she allowed the vehicle's owner to testify about what her daughter told her she saw Frances do to the car because the statement qualified as an "excited utterance" under R.I. R. Evid. 803(2); and (2) Frances knowingly and voluntarily waived her Miranda rights before speaking to the law enforcement officer, and therefore, the trial justice did not err in admitting the statement into evidence. View "In re Frances G." on Justia Law

After a jury trial, Timothy Scanlon was found guilty on six counts related to the sexual assault of a woman. The trial justice sentenced Scanlon to fifty years to serve concurrently on each of the first four counts and a suspended sentence of twenty years, with twenty years of probation on the remaining two counts. Scanlon subsequently filed a timely motion to reduce sentence. The hearing justice entered an order denying Scanlon's motion to reduce. The Supreme Court affirmed the order of the superior court, holding that the hearing justice did not abuse his discretion (1) in refusing to consider sentences that had been meted out to persons who Scanlon contended were similarly situation to him, and (2) by failing to afford Scanlon leniency in view of his family situation. View "State v. Scanlon" on Justia Law

A superior court jury found Defendant Chhoy Hak guilty of four counts of first-degree child molestation and two counts of second-degree child molestation. The trial justice sentenced Defendant to forty years imprisonment. Defendant subsequently filed a pro se motion to reduce his sentence under the provisions of rule 35 of the superior court rules of criminal procedure, which allows a trial justice to grant leniency if he or she finds the sentence originally imposed was, for any reason, unduly severe. The trial justice denied the motion. The Supreme Court affirmed, holding that Defendant failed to demonstrate that the trial justice abused his discretion when he denied Appellant's motion to reduce his sentence. View "State v. Hak" on Justia Law

After a jury trial, Defendant William Tetreault was convicted of maliciously beating and sexually assaulting his girlfriend (Complainant) and sentenced to concurrent terms of thirty years' incarceration. Defendant appealed his convictions, alleging that the trial justice erred by (1) disallowing opinion testimony as to Complainant's character for truthfulness, and (2) allowing into evidence eleven of Defendant's prior convictions, which were used to impeach his credibility as a witness. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice carefully considered the proferred evidence in both instances and did not abuse his discretion in either of the contested evidentiary rulings. View "State v. Tetreault" on Justia Law

Defendant Brian Dennis was twice convicted of felony crimes involving sexual misconduct. After Defendant's second conviction, the Sex Offender Board of Review assessed Defendant's level of risk of re-offending that he posed to the community. The Board classified Defendant as a level three, high risk sexual offender. The superior court magistrate affirmed. The Supreme Court affirmed, holding (1) the superior court magistrate did not err by finding that the State established a prima facie case justifying the Board's decision to classify Defendant as a level three sex offender; (2) Defendant was afforded a meaningful hearing when the superior court reviewed Defendant's classification level, and therefore, Defendant's right to procedural due process was not violated; (3) because the Board properly relied upon a range of materials to formulate its decision to deviate from the risk level indicated by the objective tests, the superior court magistrate did not err in finding that competent evidence existed to support the Board's assessment and upholding the classification. View "State v. Dennis" on Justia Law