Justia Rhode Island Supreme Court Opinion Summaries

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

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