Justia Rhode Island Supreme Court Opinion Summaries

In March 2022, police officers in Providence responded to concerns about Sherbert Maddox, who had not been heard from in several days. Her uncle, Marvin Maddox, reported to officers that he had been told Sherbert was killed and her body was in a refrigerator in her boyfriend’s apartment. Officers went to the apartment complex, spoke with residents, and focused on Apartment 6, where Sherbert’s boyfriend, later identified as the defendant, lived. After repeated knocking and observing someone inside who did not answer the door, officers forcibly entered the apartment without a warrant. Inside, they found the defendant, two firearms, and Sherbert Maddox’s body in a refrigerator.A grand jury indicted the defendant on nine counts, including murder and firearm offenses. Before trial in the Providence County Superior Court, the defendant moved to suppress the evidence obtained from the warrantless entry, arguing it violated his constitutional rights. After a hearing, the trial justice denied the motion, finding exigent circumstances justified the entry. At trial, several counts were dismissed, and the jury convicted the defendant of second-degree murder and related firearm charges. The defendant’s motion for a new trial was denied, and he was sentenced to consecutive life terms and additional concurrent sentences. The defendant appealed, challenging the denial of his suppression motion.The Supreme Court of Rhode Island reviewed the case, applying a clearly erroneous standard to factual findings and conducting an independent review of the constitutional issues. The Court held that exigent circumstances justified the warrantless entry and search, given the urgent need to check on Sherbert Maddox’s well-being and the information available to police at the time. The Court affirmed the Superior Court’s judgment, upholding the convictions and the denial of the suppression motion. View "State v. Cooper" on Justia Law

A father was charged with multiple counts of child molestation sexual assault involving his biological daughter, Anne, who was between the ages of three and eight during the alleged incidents. The charges included two counts of first-degree child molestation (fellatio) and two counts of second-degree child molestation (penis to vagina). The alleged acts occurred in the family home in Rhode Island, and Anne testified to both charged and uncharged incidents of sexual misconduct by the defendant, including acts that took place during family trips outside Rhode Island. Anne disclosed the abuse to her stepsister, Christine, and later to other family members, which led to a report to child protective services and a subsequent investigation.The case was tried before a jury in the Rhode Island Superior Court. The jury found the defendant guilty on one count of first-degree child molestation sexual assault (fellatio in the bathroom) and acquitted him on the remaining three counts. The trial justice admitted evidence of the defendant’s prior uncharged sexual misconduct with Anne and with Anne’s mother, Elaine, under Rule 404(b) of the Rhode Island Rules of Evidence, finding the acts sufficiently similar and nonremote to the charged conduct. The court also admitted prior consistent statements made by Anne to family members, allowed travel records into evidence, and excused a prospective juror for cause due to COVID-19 concerns.On appeal, the Supreme Court of Rhode Island reviewed five issues raised by the defendant. The Court held that the trial justice did not abuse his discretion in admitting the Rule 404(b) evidence, finding it relevant, necessary, and not unfairly prejudicial. The Court also found no error in the admission of prior consistent statements, the travel records, or the excusal of the juror. The Court affirmed the judgment of conviction and remanded the case to the Superior Court. View "State v. Montero" on Justia Law

The defendant was convicted by a jury of three counts of assault with a dangerous weapon, conspiracy to commit assault with a dangerous weapon, drive-by shooting, and conspiracy to commit a drive-by shooting. The incident occurred on September 12, 2020, when the defendant and a group of friends encountered another group, leading to a shooting that injured three individuals. The defendant was identified as the driver of the vehicle from which the shots were fired. The police investigation led to the arrest of the defendant and the recovery of the firearm used in the shooting.In the Superior Court, the defendant was found guilty on all counts and sentenced to concurrent terms for the assault and conspiracy charges, with additional sentences for the drive-by shooting and conspiracy to commit a drive-by shooting. The defendant appealed, arguing that the trial justice erred in several ways, including not admitting a witness's juvenile record, improperly admitting hearsay evidence, denying his motion for a new trial, and denying his motion for a judgment of acquittal.The Rhode Island Supreme Court reviewed the case and upheld the trial court's decisions. The court found that the trial justice did not abuse her discretion in excluding the juvenile record, as the defendant did not sufficiently alert the trial justice to the specific rule of evidence he was relying on. The court also determined that the hearsay statement about a "blinky" was properly admitted to show its effect on the listener, not for the truth of the matter asserted.The court affirmed the denial of the motion for a new trial, concluding that the trial justice had thoroughly reviewed the evidence, made credibility determinations, and found the testimonies of key witnesses credible. The court also upheld the denial of the motion for a judgment of acquittal, finding that the evidence was sufficient to support the jury's verdict. The judgment of conviction was affirmed, and the case was remanded to the Superior Court. View "State v. Peckham" on Justia Law

A man was indicted for first-degree sexual assault based on an incident that occurred in July 1999, in which the complaining witness testified that the defendant, whom she had known for less than two weeks and considered only a platonic friend, visited her home unannounced and forcibly raped her. The witness described her resistance and the emotional and psychological trauma she suffered afterward. DNA evidence collected at the time of the incident was later matched to the defendant. The prosecution also presented testimony from medical and forensic experts, as well as corroborating testimony from the witness’s friend, who received a distressed call from her shortly after the event.The case proceeded to a jury trial in the Providence County Superior Court in 2022, nearly twenty-three years after the alleged assault. The jury found the defendant guilty, and the trial justice denied his motion for a new trial. The defendant was sentenced to thirty-five years, with twelve years to serve and the remainder suspended with probation. The defendant appealed, arguing that the trial justice erred by refusing to instruct the jury on the defense of consent, by not giving a spoliation instruction regarding missing physical evidence (the jeans the witness wore), and by issuing an Allen charge to the deadlocked jury rather than declaring a mistrial.The Supreme Court of Rhode Island reviewed the case and affirmed the Superior Court’s judgment. The Court held that the trial justice’s instructions on force and coercion were adequate and that a separate consent instruction was unnecessary because there was no evidence of consent. The Court also found no error in refusing a spoliation instruction, as there was no evidence of bad faith or exculpatory value in the missing jeans. Finally, the Court concluded that the Allen charge given to the jury was fair, neutral, and not coercive under the circumstances. View "State v. Threadgill" on Justia Law

The defendant and the victim were involved in a fatal shooting that occurred outside the home of the defendant’s former partner, with whom he shared a child. After the end of their romantic relationship, the former partner began seeing the victim. On the night in question, the victim arrived at the former partner’s house, and after an encounter between the defendant and his former partner, the defendant fired multiple gunshots into the victim’s car, resulting in the victim’s death. The defendant was subsequently indicted on multiple charges, including murder and several related offenses. Additional charges were brought based on the defendant’s conduct while incarcerated awaiting trial. The two cases were consolidated and tried together.In the Providence County Superior Court, the defendant was tried before a jury. The trial justice included an instruction on voluntary manslaughter over the state’s objection, but instructed the jury to consider voluntary manslaughter only if it found the state had not proven first- or second-degree murder beyond a reasonable doubt. The defendant objected, arguing that the jury should be allowed to consider whether adequate provocation negated malice even if the elements of murder were otherwise satisfied, and that the state should be required to disprove provocation beyond a reasonable doubt. The jury found the defendant guilty of second-degree murder and several other charges, and not guilty on others. The defendant was sentenced accordingly and appealed.The Supreme Court of Rhode Island reviewed the case. The court held that the trial justice’s instructions were proper, finding that the instructions, when viewed in their entirety, adequately explained the law and did not mislead the jury. The court concluded that the state’s burden of proof was not improperly shifted to the defendant and that the instructions did not violate due process. The judgments of conviction were affirmed. View "State v. Mangru" on Justia Law

The defendant, Olayinka Alege, was charged with one count of simple assault and/or battery following an incident at the Edge Fitness club in Warwick, Rhode Island, where he allegedly removed a complaining witness's sock and shoe and massaged his foot without consent. The Warwick Police Department filed a criminal complaint on May 10, 2021, and the defendant was found guilty in the Third Division District Court on April 8, 2022. The case was then transferred to the Superior Court, where a mistrial was declared due to a hung jury. A new trial was scheduled, and the defendant's counsel withdrew, leading to the defendant representing himself.In the Superior Court, the defendant's motion for a Franks hearing was denied. The trial justice found that the statement in the affidavit, which indicated that surveillance video supported the complaining witness's version of events, was not materially false and that the complaining witness's statement alone supported probable cause. The trial justice also granted the state's motion in limine to admit testimony from Alexander Harrington under Rule 404(b) of the Rhode Island Rules of Evidence, finding it relevant to show intent or plan.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's judgment. The Court held that the trial justice did not abuse his discretion in denying the Franks hearing, as the affidavit contained sufficient content to support probable cause. The Court also upheld the admission of Harrington's testimony, agreeing that it was relevant to show intent or plan and that the trial justice provided appropriate limiting instructions to the jury. The Court found no error in the trial justice's denial of the defendant's motion to recuse, noting that the trial justice's actions demonstrated no personal bias or prejudice. Finally, the Court declined to consider the defendant's argument regarding sentencing, as he had not filed a Rule 35 motion and presented no extraordinary circumstances. View "State v. Alege" on Justia Law

The defendant was arrested by the Rhode Island State Police on January 13, 2017, following allegations of child molestation by the complainant, A.R. During the post-arrest interview, the defendant admitted to various instances of sexual contact with A.R. Subsequently, the state filed a ten-count criminal information against the defendant, including eight counts of second-degree child molestation. The defendant moved to suppress his post-arrest statements, arguing they were involuntary and obtained in violation of his due process rights and Rule 5(a) of the District Court Rules of Criminal Procedure. He also sought to introduce expert testimony on false confessions, which the state moved to preclude.The Superior Court denied the defendant's motion to suppress, finding that his statements were made voluntarily and that the delay in presentment to the District Court was not causative of his confession. The court also granted the state's motion in limine to exclude the expert testimony on false confessions, reasoning that it would invade the jury's province and that effective cross-examination of the police would suffice. The jury found the defendant guilty on five counts of second-degree child molestation, and the trial justice denied the defendant's motion for a new trial.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's judgment. The Court held that the trial justice did not err in denying the motion to suppress, as the defendant's statements were made voluntarily under the totality of the circumstances. The Court also upheld the exclusion of the expert testimony on false confessions, agreeing that it would improperly influence the jury's role in determining credibility. Finally, the Court found no error in the trial justice's denial of the motion for a new trial, as the trial justice had appropriately evaluated the evidence and witness credibility. View "State v. Coletta" on Justia Law

The case involves allegations of child molestation against the defendant, who was indicted on one count of first-degree child molestation and two counts of second-degree child molestation. The complaining witness, a minor, accused the defendant of multiple instances of molestation occurring when she was between four and eight years old. The defendant was convicted by a jury on one count of first-degree child molestation and one count of second-degree child molestation. He was sentenced to a sixty-year sentence, with twenty-five years to be served, for the first-degree count, and a concurrent twenty-five-year sentence for the second-degree count.In the Providence County Superior Court, the trial justice granted the defendant’s motion for judgment of acquittal on one of the two counts of second-degree child molestation. The jury found the defendant guilty on the remaining counts. The defendant did not file a motion for a new trial. The trial justice later sentenced the defendant, and a judgment of conviction and commitment was entered.The defendant appealed to the Supreme Court of Rhode Island, arguing that the trial justice erred by allowing a medical expert to testify in a manner that impermissibly bolstered the complaining witness’s testimony. The Supreme Court of Rhode Island reviewed the case and determined that the defendant had not properly preserved his objection to the expert’s testimony for appellate review. The court noted that the defendant failed to object to the specific questions that formed the basis of his appeal and did not move to strike the expert’s answers or request a cautionary instruction. Consequently, the court deemed the issue waived and affirmed the judgment of the Superior Court. View "State v. Lantigua" on Justia Law

In the early morning of June 26, 2018, David Page was shot and killed while picking up acquaintances at 100 Lowell Avenue. The Providence Police Department (PPD) responded and found Mr. Page unresponsive in his car. Surveillance footage showed a black vehicle near the scene. On July 2, 2018, during unrelated investigations, police found a black Audi linked to Kennedy Terrero. Further investigation connected this Audi to the shooting. Terrero, under a cooperation agreement, testified against Jaythan Hang and Chandanoeuth Hay, implicating them in the shooting.The Superior Court jury found Hang guilty of first-degree murder, conspiracy, felony assault, and firearms offenses. Hang appealed, arguing the trial justice erred in several pretrial and trial rulings, including denying a motion for severance, admitting evidence of prior bad acts, admitting statements against interest, and allowing lay opinion testimony. He also challenged the denial of his motion for a new trial on the conspiracy count.The Rhode Island Supreme Court reviewed the case. It found no abuse of discretion in the trial justice's decisions. The court held that the evidence of prior bad acts was admissible to show motive and intent, and the lay opinion testimony was properly admitted. The court also found sufficient evidence to support the conspiracy conviction, noting the corroborative evidence and testimony presented at trial. The Supreme Court affirmed the Superior Court's judgment of conviction. View "State v. Hang" on Justia Law

The defendant was indicted on charges including first-degree robbery, conspiracy, discharging a firearm during a crime of violence, assault with a dangerous weapon, and possessing pistols without licenses. He reached a plea agreement with the state, which included a maximum sentence of eighty years with fifty years to serve, twenty of which would be nonparolable, and a thirty-year suspended sentence. The defendant pled guilty, and the trial justice accepted the plea and sentenced him to a term of twenty years, a concurrent term of ten years, a consecutive term of twenty years without parole, a consecutive suspended sentence of twenty years, and a concurrent suspended sentence of ten years.The defendant filed a motion to reduce his sentence under Rule 35, arguing that the trial justice misconceived material evidence and failed to consider mitigating factors. The state objected, asserting that the defendant had forfeited his right to file a Rule 35 motion as part of his plea agreement. The trial justice denied the motion, finding no grounds for relief, and the defendant appealed.The Rhode Island Supreme Court reviewed the case and found that the trial justice did not demonstrate prejudice or personal bias against the defendant, and his decision not to recuse himself was proper. The court also held that the trial justice did not abuse his discretion in denying the Rule 35 motion, as the defendant's sentence was below the statutory maximum and the agreed-upon cap. The court affirmed the order of the Superior Court. View "State v. McLean" on Justia Law