Articles Posted in Constitutional Law

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The Supreme Court vacated the judgment of conviction after a jury found Defendant guilty of first degree sexual assault and murder, holding that Defendant was entitled to a new trial because the trial court violated the Confrontation Clause. In this cold case, Defendant was charged with the crimes for which he was convicted twenty-five years after the victim was murdered. On appeal, Defendant argued, among other things, that the trial justice erred by allowing statements of deceased declarants to be admitted into evidence, in violation of the Confrontation Clause. The Supreme Court agreed and vacated Defendant’s convictions, holding (1) the Confrontation Clause was violated when the State implicitly conveyed to the jury the content of statements made by deceased witnesses, both through a detective’s testimony and the closing argument of the prosecutor; and (2) these violations were not harmless beyond a reasonable doubt. The Court remanded the case to the superior court for a new trial. View "State v. Roscoe" on Justia Law

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The Supreme Court quashed the judgment of the superior court that granted Defendant’s application for postconviction relief and reinstated Defendant’s convictions, holding that the hearing justice erred in holding that trial counsel rendered ineffective assistance in certain respects. The Supreme Court reinstated Defendant’s conviction with respect to aiding-and-abetting counts for felony murder, robbery, using a firearm in the commission of a crime o violence, discharging a firearm in the commission of a crime of violence, and committing a crime of violence while armed and having available a firearm. Specifically, the Supreme Court held (1) trial counsels’ performance was not deficient in failing to propose aiding-and-abetting jury instructions in line with Rosemond v. United States, 572 U.S. 65 (2014), because that case was inapplicable here; and (2) the hearing justice erred when she held that trial counsel rendered ineffective assistance by failing to challenge the sufficiency of the evidence with respect to an aiding-and-abetting theory. View "Whitaker v. State" on Justia Law

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The Supreme Court affirmed the judgment of the superior court finding Defendant guilty of one count of second-degree murder and one count of discharging a firearm while committing a crime of violence, holding that the trial justice did not err in denying Defendant’s motion to suppress or in failing to exclude certain evidence. Specifically, the Court held (1) law enforcement’s failure to comply with Miranda does not require the suppression of the physical evidence acquired as a result of a suspect’s unwarned, but voluntary, statements; (2) Defendant’s statements leading detectives to a firearm and ammunition were voluntary, and therefore, the gun and ammunition were admissible; and (3) the trial justice did not err in concluding that the police’s seizure through the impounding of Defendant’s vehicle and the subsequent search of the vehicle were constitutional, and therefore, the evidence obtained therein admissible. View "State v. Beauregard" on Justia Law

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The Supreme Court affirmed the judgment of the superior court denying Appellant’s application for postconviction relief, holding that Appellant was not entitled to postconviction relief. Appellant was found guilty of murder in the first degree and other offenses and sentenced to life imprisonment. Appellant later filed the instant application for postconviction relief alleging that he was denied effective assistance of trial and appellate counsel. After a hearing, the hearing justice denied the application for postconviction relief. The Supreme Court affirmed, holding that there was no ineffective assistance of either Appellant’s trial or appellate counsel, and therefore, the hearing justice properly denied Appellant’s application for postconviction relief. View "Jimenez v. State" on Justia Law

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The Supreme Court affirmed the order of the superior court denying Defendant’s motion to reduce a sentence, holding that the trial justice was within his discretion to give and confirm the punishment for Defendant. Defendant was convicted of one count of first-degree child molestation sexual assault. Defendant was originally sentenced to a forty-year term to serve but, after the case was remanded, he was sentenced to life imprisonment. Defendant filed a motion to reduce the sentence, arguing that the life sentence imposed after the second trial was unconstitutional. The trial justice denied the motion. Defendant appealed, arguing that the trial justice abused his discretion by imposing a sentence significantly longer than the sentence imposed after his first conviction. The Supreme Court affirmed, holding that the trial justice properly decided to impose the maximum sentence permitted under the statute in this case and that Defendant failed to demonstrate that the sentence was grossly disparate from other sentences generally imposed for similar offenses. View "State v. Oliveira" on Justia Law

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The Supreme Court affirmed Defendant’s conviction for carrying a firearm without license and other firearm-related offenses. After Defendant filed his appeal, he filed in the Supreme Court a motion to hold the appeal in abeyance and remanded the matter to the superior court to allow him to seek a new trial based on alleged violations of Brady v. Maryland, 373 U.S. 83 (1963). The Court denied Defendant’s motion to hold the appeal in abeyance but granted the remand motion. A hearing on the alleged Brady violation was held before the same justice of the superior court who presided over Defendant’s trial. The trial justice denied both the Brady-related motion for a new trial and Defendant’s motion to recuse the trial justice. The Supreme Court affirmed, holding that the trial justice did not commit prejudicial error by (1) denying Defendant’s motion to suppress two witnesses’ show-up identifications; (2) admitting the recording of an anonymous 911 call at trial; (3) determining that the state did not commit a Brady violation; and (4) denying Defendant’s motion to recuse the trial justice. View "State v. Washington" on Justia Law

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The Supreme Court affirmed the judgment of the superior court dismissing Plaintiffs’ second amended complaint with prejudice, holding that the hearing justice did not err in dismissing the complaint. In their second amended complaint, Plaintiffs challenged the constitutionality of the statutory system for appointing magistrates to the Rhode Island Traffic Tribunal. Specifically, Plaintiffs claimed that they were due a refund of fines and costs that had previously been assessed by the Traffic Tribunal because Defendants’ conduct was unconstitutional. Plaintiffs further argued that Defendants had been unjustly enriched by levying those fines. Defendants moved to dismiss Plaintiffs’ complaint with prejudice pursuant to Rules 12(b)(1) and 12(b)(6) of the Superior Court Rules of Civil Procedure. The justice granted the motion. The Supreme Court affirmed, holding that Plaintiffs’ complaint failed to state a viable claim for relief as to Plaintiffs’ constitutional claim and that the complaint failed to allege the facts necessary to support the unjust enrichment claim. View "McKenna v. Guglietta" on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of two counts of first-degree sexual assault. On appeal, Defendant argued, among other things, that the trial justice should have granted his motion for a mistrial due to what he termed the prosecutor’s comment on his failure to testify. The Supreme Court held (1) the trial justice correctly found that the prosecutor’s statement, taken in context, did not improperly comment on Defendant’s failure to testify and thus did not violate Defendant’s Fifth Amendment rights; (2) the trial justice did not commit reversible error in admitting Defendant’s “mug shot” into evidence; and (3) the trial justice did not err by denying Defendant’s motion for new trial. View "State v. Marizan" on Justia Law

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The Supreme Court vacated the judgment of the superior court denying Petitioner’s application for postconviction relief, in which he alleged that his constitutional rights were violated when his parole was revoked and he was denied the possibility of parole in the future. After Petitioner was granted parole, he was arrested in Pennsylvania and convicted of one count of aggravated assault. In 1994, while Petitioner was serving his sentence in Pennsylvania, the Rhode Island Parole Board voted to revoke Petitioner’s parole and indicated that he would no longer be eligible for parole. Upon completion of his prison term in Pennsylvania, Petitioner, in 2014, appeared again before the Parole Board. The Parole Board affirmed the revocation of Petitioner’s parole and stated that Petitioner would forever remain ineligible for parole consideration. The Supreme Court held that it was error for the Parole Board to have denied Petitioner counsel at the 1994 hearing and the 2014 hearing and remanded the case with instructions that the superior court remand this case to the Parole Board to conduct a new parole revocation hearing. View "Jefferson v. State" on Justia Law

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The Supreme Court affirmed the judgment of the superior court denying Defendant’s application for postconviction relief in which Defendant argued that he had received ineffective assistance of counsel because his lawyer was not licensed to practice law in Rhode Island. Defendant pled nolo contendere to two criminal offenses and admitted to violating his probationary sentence. In his postconviction relief application, Defendant argued that he received ineffective assistance of counsel because his defense counsel, who was not licensed to practice law in Rhode Island, was engaging in unlawful conduct. Defendant further argued that his defense counsel’s associate, who was licensed in Rhode Island and who appeared in court with Defendant, was a “straw man” and thus complicit in the scheme to practice law without a license. The superior court denied the application. The Supreme Court affirmed, holding (1) the trial justice properly found that defense counsel’s associate, not defense counsel, represented Defendant with respect to his pleas; and (2) Defendant’s argument that defense counsel and the associate had a conflict of interest in representing Defendant lacked merit. View "Millette v. State" on Justia Law