Justia Rhode Island Supreme Court Opinion Summaries

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

When Neighborhood Health Plan of Rhode Island (NHP), a not-for-profit corporation that operated a licensed health maintenance organization that provided health insurance coverage to its enrollees, began reimbursing ophthalmologists at a higher rate than the rate paid to optometrists for performing the same services, two optometrists brought an action on behalf of all optometrists who had entered into participating provider agreements with NHP during the period that the differential reimbursement policy was in effect, contending that this differential reimbursement violated state law. The superior court granted summary judgment in favor of NHP, reasoning that the antidiscrimination provision in R.I. Gen. Laws 5-35-21.1(b) applied only to expenditures of public funds and that NHP did not violate the statute because NHP paid for the ophthalmologists' services using private money. The Supreme Court affirmed, holding (1) the statute at issue was not ambiguous; and (2) the motion justice did not err in concluding that NHP is not an agency or department of the state and cannot otherwise be considered a state actor. View "Drs. Pass and Bertherman, Inc. v. Neighborhood Health Plan of R.I." on Justia Law

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