Justia Rhode Island Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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In this case decided by the Supreme Court of Rhode Island, the defendant, Mark Chez, appealed his conviction for carrying a pistol without a license. The case stemmed from an incident on May 30, 2020, when a police officer, in an unmarked police car, observed Chez in a suspicious situation. The officer recognized Chez as having outstanding arrest warrants. When the police moved towards the vehicle where Chez was seated, Chez fled, during which the officer observed him throw an object, believed to be a firearm, from his pocket. A police dog subsequently located a firearm in the area where the officer saw Chez discard the object.Chez was charged, tried, and convicted of carrying a pistol without a license. On appeal, Chez argued that the trial justice erred in denying his motion for a judgment of acquittal and his motion for a new trial, contending that the evidence was insufficient to support his conviction, and that the weight of the evidence did not support the jury's verdict.The Supreme Court, after a de novo review of the evidence, held that there was more than sufficient evidence to support a reasonable inference of guilt beyond a reasonable doubt. The court noted that Chez was recognized by multiple officers, was observed running away from the police with a weighted object in his pocket, and that a firearm was discovered in the specific area where an officer observed him throw the object. Accordingly, the Supreme Court affirmed the judgment of the Superior Court, upholding Chez's conviction. View "State v. Chez" on Justia Law

Posted in: Criminal Law
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In this case heard by the Supreme Court of Rhode Island, Somayina Odiah, the defendant, was appealing his conviction for one count of indecent solicitation of a child. The defendant had been communicating online with a person he believed to be a 14-year-old transitioning from male to female named “Alice.” However, “Alice” was a fictitious character created by the Rhode Island State Police for an undercover operation. The defendant was arrested after arranging to meet “Alice” in person. The defendant's argument on appeal focused on the claim that the state had not proven that “Alice” was “over the age of fourteen,” a necessary element for the charged offense.The Supreme Court of Rhode Island affirmed the conviction. It held that even if “Alice” had turned fourteen on the day of the charged offense, under Rhode Island law, a person reaches their next year in age at the first moment of the day prior to the anniversary date of their birth. Therefore, “Alice” would have been considered to be exactly fourteen years old on the day before the charged offense. The court concluded that the defendant was planning to meet a fourteen-year-old child, with whom he had communicated about sexual activity, and that the trial justice did not err in denying the motion to dismiss the charge on the basis of the state not proving "Alice" was "over the age of fourteen." Thus, the defendant's judgment of conviction was affirmed. View "State v. Odiah" on Justia Law

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The Supreme Court vacated the orders of the superior court granting Defendants' motions to suppress evidence of approximately ninety-four pounds of marijuana seized from one defendant's vehicle during a traffic stop, holding that the trial justice erred in granting Defendants' motions to suppress.Junjie Li was operating a vehicle and Zhong Kuang was in the passenger seat when a law enforcement officer initiated a traffic stop. While conversing with Li, the officer noticed Li began to exhibit nervous behavior and detected an order of marijuana coming from inside Kuang's vehicle. After a dog sniff, officers discovered marijuana. Li and Kuang moved, individually to suppress the marijuana. The trial justice granted the motions to suppress, holding that the extension of the traffic stop beyond its original scope was unreasonable because the officer did not have independent reasonable suspicion to prolong the stop. The Supreme Court vacated the superior court's orders, holding that the trial justice erred in concluding that the officer did not possess reasonable suspicion to prolong the stop based on the totality of the circumstances. View "State v. Li" on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of operating a vehicle in reckless disregard of the safety of others, death resulting, and operating a vehicle in reckless disregard of the safety of others, personal injury resulting, holding that there was no error.Specifically, the Supreme Court held (1) the trial justice properly exercised her judgment, did not overlook or misconceive the testimony in evidence, and provided adequate reasons supporting her denial of Defendant's motion for a new trial based on the weight of the evidence; and (2) Defendant's argument that the trial justice erred by admitting evidence from an electronic data recovery system obtained from one of a tow truck involved in the underlying automobile accident was waived. View "State v. Savard" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the orders of the superior court granting motions to suppress filed by Defendants Jerome Joseph and Voguel Figaro, holding that the hearing justice did not err in granting Defendants' suppression motions.Figaro moved to suppress physical evidence seized as the result of a motor vehicle stop, arguing that the officer unconstitutionally prolonged the stop to perform a dog sniff. Joseph also filed a motion to suppress and joined the memorandum supporting Figaro's suppression motion. The hearing justice granted the motions to suppress, holding that reasonable suspicion did not support the prolonged traffic stop of Figaro's vehicle. The Supreme Court affirmed, holding that the hearing justice properly found that the state police lacked reasonable suspicion to detain Defendants. View "State v. Joseph" on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of three counts of first-degree sexual assault, following a jury trial, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme eCourt held that the trial justice (1) did not violate Defendant's constitutional right to present a defense by excluding the proposed expert testimony of Dr. Patricia R. Recupero as not relevant under Rule 401 of the Rhode Island Rules of Evidence; (2) did not err in instructing the jury that there was no need for certain testimony to be corroborated in order to support a guilty verdict; and (3) did not abuse his discretion in limiting the redirect examination of Defendant about his preparation for trial. View "State v. Robinson" on Justia Law

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The Supreme Court affirmed the judgment of the superior court denying Defendant's motion for entry of a judgment of acquittal and convicting him on thirteen counts stemming from his alleged misuse of his position as detective commander in the Middletown Police Department, holding that Defendant's argument on appeal was waived.Defendant was convicted of several counts for assisting an individual to attain a house choice voucher from the Newport Housing Authority. Defendant appealed the denial of his motion for judgment of acquittal on the basis of his contention that "[a]ny rules governing the user's behavior within the system are irrelevant and cannot contribute to the sufficiency of the state's case in a [Sup. Ct. R. Crim. P. 29] motion...." The Supreme Court affirmed, holding that Defendant's argument was waived because it was not the same argument he made below. View "State v. Gamache" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court convicting and committing Defendant on one count of first-degree sexual assault after a jury trial, holding that there was no prejudicial error in the proceedings below.Defendant was convicted after a jury trial and sentenced to thirty-eight years at the Adult Correctional Institutions. On appeal, Defendant challenged the ruling of the trial justice permitting the State to introduce into evidence testimony given by a nurse concerning what the complaining witness told her about the alleged sexual assault. The Supreme Court affirmed, holding (1) Defendant's arguments on appeal were properly before the Court; (2) the was no error in the discretionary decision of the trial justice to admit the nurse's testimony; and (3) certain portions of admitted statements were erroneously admitted, but the evidence was clearly harmless cumulative evidence. View "State v. White" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the decision of the superior court dismissing Plaintiffs' claims in favor of Defendants in accordance with Sup. Ct. R. Civ. P. 12(b)(6), holding that the trial court did not err in ruling that R.I. Gen. Laws 9-1-51 (the act), as amended, created a class of criminal actors beyond the scope of actual perpetrators as set forth in the act.Plaintiffs filed separate actions alleging that they were sexually molested as minors by priests at the Roman Catholic Diocese of Providence. Plaintiffs claimed that Defendants' actions rose to the level of criminal aiding and abetting, thus constituting improper conduct. The trial justice granted Defendants' motions to dismiss all claims in all cases, holding that because Defendants were non-perpetrators, the actions were time-barred. The Supreme Court affirmed, holding (1) Defendants could not be found culpable as aiders or abettors; (2) even if Defendants' actions constituted a violation of a criminal statute, they were non-penetrators and the claims were time-barred; and (3) there was no other error. View "Houllahan v. Gelineau" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court convicting Defendant of two counts of second-degree sexual assault, holding that the trial justice did not err in denying Defendant's motion to pass the case or his motion for a new trial.Defendant was convicted after a trial. The trial justice denied Defendant's motion for a new trial and sentenced him to eight years of imprisonment for each count, with one year to serve and the remaining time suspended. On appeal, Defendant argued, among other things, that the trial justice abused his discretion in denying Defendant's motion to pass the case due to the prosecutor's allegedly improper comments during closing arguments. The Supreme Judicial Court affirmed, holding (1) the trial justice did not abuse his discretion in denying Defendant's motion to pass the case; and (2) the trial justice did not erroneously admit evidence unduly prejudicial to Defendant, and therefore, Defendant was not entitled to receive a new trial. View "State v. Leonard" on Justia Law

Posted in: Criminal Law