Justia Rhode Island Supreme Court Opinion Summaries

Two men, Jamal Cruz and Rokiem Henley, attended a nightclub in Providence with friends. After the club closed, Cruz had a brief verbal disagreement with two other men, including Terrel Barros and Stephen Bodden. As Cruz and Henley were leaving, Bodden confronted Cruz outside, followed by gunshots that injured Henley and fatally wounded Cruz. Police officers nearby responded quickly, saw Bodden and Barros get into a car, and arrested both men. Barros was subsequently charged and convicted of first-degree murder and several related offenses, largely based on Cruz’s dying identification, eyewitness testimony, and evidence presented at trial.Following his conviction, Barros filed an application for postconviction relief in the Rhode Island Superior Court, alleging several constitutional violations, actual innocence, and the existence of newly discovered evidence. During the postconviction hearing, Barros introduced testimony from Gloria Parajon, Bodden’s cousin, who stated that Bodden had privately confessed to her, on multiple occasions, that he was the shooter. The hearing justice found Parajon’s testimony to be newly discovered, credible, and not merely cumulative, and concluded it could change the verdict at a new trial. The Superior Court granted Barros’s application for postconviction relief and vacated his conviction.On review, the Supreme Court of Rhode Island determined that the Superior Court did not err in admitting Parajon’s testimony as a statement against penal interest under Rule 804(b)(3) of the Rhode Island Rules of Evidence, and that her statements were sufficiently corroborated. The Supreme Court affirmed the judgment of the Superior Court, holding that Barros was entitled to postconviction relief based on newly discovered evidence, and remanded the case for further proceedings. View "Barros v. State of Rhode Island" on Justia Law

On May 14, 2021, several siblings and friends gathered at a residence in Providence, Rhode Island, using a Nissan Murano to run errands and socialize. Later that evening, they met Tyreik Grundy, who arrived in a Honda Civic. Both cars parked in a lot across from the residence. While the group was in and around the Murano, two individuals approached, and one fired several shots into the vehicle, killing Grundy. The shooter was described as wearing a red hoodie and gloves, and DNA evidence from a smudge on the Murano’s rear passenger window was later linked to the defendant. Surveillance footage and cell phone data were used to tie a white Infiniti, allegedly associated with the defendant, to the scene.The Providence County Superior Court jury convicted the defendant of first-degree murder, conspiracy to commit assault with a dangerous weapon, discharging a firearm during a crime of violence resulting in death, and carrying a pistol without a license. After the verdict, the defendant filed a motion for a new trial, arguing the evidence was insufficient to establish he was the shooter and that the jury misapplied the law. The trial justice denied the motion, finding the circumstantial evidence—car, cell phone, and DNA—supported the verdict and that reasonable minds could differ about the defendant’s culpability.On appeal, the Supreme Court of Rhode Island reviewed the denial of the motion for a new trial. The Court concluded that the trial justice had not sufficiently articulated her reasoning as the “thirteenth juror,” specifically failing to explain how she weighed the evidence and whether she agreed with the jury’s verdict. As a result, the Supreme Court vacated the denial of the motion for a new trial and remanded the case to the Superior Court for a new hearing on the motion. View "State v. Page" on Justia Law

Police investigating suspected drug trafficking received information from a confidential informant about two individuals selling drugs. Surveillance linked the suspects to multiple addresses. The investigation included controlled drug buys and installation of a pole camera outside an apartment building. On April 4, 2023, the informant reported a possible deceased person inside one of the apartments. Surveillance footage showed the suspects and another individual entering and exiting the building. Police detained the suspects at a traffic stop and seized keys. Officers then entered the apartment building without a warrant, finding a deceased person in the second-floor apartment and, upon entering the third-floor apartment, discovering drug paraphernalia and contraband.The Providence County Superior Court held a hearing on the defendant’s motion to suppress evidence obtained during the warrantless search and seizure. The trial justice denied the motion, concluding that the police were responding to a sudden emergency involving a possible death and acted rationally to protect citizens from harm and prevent destruction of property. The defendant was subsequently found guilty on all charges following a bench trial and sentenced to twenty-five years, with twenty years to serve and five years suspended. The defendant appealed.The Supreme Court of Rhode Island reviewed the denial of the motion to suppress under the Fourth Amendment and article 1, section 6 of the Rhode Island Constitution, applying the totality of the circumstances standard and deferring to factual findings unless clearly erroneous. The Court held that police had no constitutionally permissible reason to enter the third-floor apartment after finding the deceased in the second-floor apartment and that the exigency justifying entry had evaporated. The Court concluded that the error was not harmless, vacated the conviction, and remanded for a new trial. View "State v. Moronta" on Justia Law

The case centers on the fatal shooting of a seventeen-year-old during a street altercation in Providence, Rhode Island. The defendant was accused of firing a gun at the victim as she approached a fight between her sister and the defendant’s sister. Witnesses saw the defendant shoot in the victim’s direction, after which she collapsed and later died at the hospital. The defendant was apprehended and charged with second-degree murder and two firearms offenses.At the initial trial in the Rhode Island Superior Court, the prosecution exercised a peremptory strike against the only African-American prospective juror. The trial court allowed the strike, accepting the prosecutor’s asserted concern about potential workplace repercussions for the juror. The jury, which had no African-American members, convicted the defendant on the main charges. On appeal, the Rhode Island Supreme Court upheld the conviction, finding the peremptory strike was based on race-neutral grounds. After a habeas petition was denied by the federal district court, the United States Court of Appeals for the First Circuit reversed, holding that the strike was not race-neutral and ordered the state courts to vacate the conviction unless a new trial was held.At the retrial, again only one African-American venireperson was present. The prosecution sought to remove this juror for cause and, when that was denied, exercised a peremptory challenge, citing the juror’s pending criminal cases and lack of candor. The trial justice ultimately allowed the peremptory challenge, and a jury again lacking African-Americans convicted the defendant. The defendant’s motion for a new trial was denied.On appeal, the Supreme Court of Rhode Island held that the trial court failed to properly conduct the third step of the Batson analysis, which requires a probing inquiry into whether the prosecutor’s race-neutral explanation was genuine or pretextual. The court concluded this failure constituted structural error and vacated the conviction, remanding the case for a new trial. View "State v. Porter" on Justia Law

On the morning of September 25, 2021, Julio Castro saw Jorge Garcia, an acquaintance, at Roque’s Café in Providence, Rhode Island. Garcia was accompanied by his employer, Arturo Walker. Prior to this encounter, Juan Rivera, a friend of Castro, had inquired about Garcia, expressing an interest in discussing drugs with him. After a brief exchange at the café, Garcia was fatally shot by an individual captured on surveillance footage wearing a black sweatshirt with white lettering. Police determined the shooter arrived at the scene with another person in a red Toyota with a black hood and linked a black Dodge Ram at the scene to Rivera. Further investigation, including witness testimony and video evidence, implicated Rivera, who was later charged with multiple offenses including first-degree murder.After the incident, the Providence County Superior Court conducted a jury trial. The state introduced surveillance footage and other evidence, including statements from a now-deceased individual, Josue Calderon, and testimony from Isamarys Segura. Rivera’s defense objected to the admission of certain surveillance videos, argued hearsay exceptions were improperly applied to Calderon's statements, and challenged the admissibility of testimony about “the word on the streets.” The jury found Rivera guilty on all counts, and he was sentenced to two consecutive life terms plus additional concurrent sentences for the other offenses.The Supreme Court of Rhode Island reviewed the convictions. The court held that the trial justice did not abuse her discretion in admitting the surveillance footage, finding the foundation for authenticity under Rule 901 was sufficiently established through expert testimony. The court also determined that the defense failed to preserve objections to Calderon's statements and Segura’s testimony for appellate review, as contemporaneous objections were not made at trial. Accordingly, the court affirmed the Superior Court’s judgment. View "State v. Rivera" on Justia Law

The defendant was indicted for first-degree sexual assault following an incident in March 2021. The complainant testified that she was invited to a social gathering by the defendant, consumed alcohol throughout the night, and later awoke in an unfamiliar motel room unable to move, where she observed the defendant engaging in sexual acts against her will. The complainant denied consenting to sexual activity or going to the motel. A motel employee corroborated that the complainant appeared intoxicated, and forensic testing on her clothing and swabs revealed DNA consistent with the defendant. The defendant conceded to sexual intercourse but claimed it was consensual.The case was tried before the Kent County Superior Court, where a jury heard testimony from the complainant, witnesses, and forensic experts. The laboratory supervisor who reviewed and approved the DNA analysis, but did not perform the testing herself, testified regarding the DNA findings. The defendant moved to strike her testimony, arguing it violated his right to confront the analyst who performed the testing, relying on Supreme Court precedents. The trial justice denied the motion, referencing prior Rhode Island Supreme Court decisions permitting supervisory analysts to testify.On appeal, the Supreme Court of Rhode Island reviewed whether the defendant properly preserved his Confrontation Clause objection and whether an intervening Supreme Court decision, Smith v. Arizona, warranted a departure from the raise-or-waive rule. The Court held that the defendant’s objection was not based on a novel rule of law and was untimely, as prior precedent already addressed the issue. The Court concluded that the intervening decision did not alter existing controlling law and affirmed the Superior Court’s judgment of conviction. View "State v. Vasquez" on Justia Law

A man was convicted of two counts of first-degree child molestation based on events that began in 2005, when the complainant was ten years old. The complainant, who lived with her mother, became acquainted with the defendant through her older sister and neighbors. After the defendant briefly lived with the complainant’s mother and had a short romantic relationship with her, the defendant and the complainant began spending time together. Their interactions gradually became more physical, progressing to frequent sexual activity, including digital and penile-vaginal penetration, while the complainant was still under fourteen years old. These acts occurred both while the complainant’s mother was at home and during times when she was absent, such as a week-long hospital stay.After several years and a disclosure to her mother and others, the complainant’s allegations were reported to the Rhode Island State Police. The defendant was interviewed by detectives at police headquarters. During the interview, after being informed of his Miranda rights, the defendant invoked his right to counsel, and questioning ceased. However, outside the station, the defendant initiated further conversation with the detective, during which he made incriminating statements. The defendant was later indicted in 2016 after earlier grand jury proceedings did not result in charges.The Rhode Island Superior Court denied the defendant’s motion to suppress his statements to police, finding he was not in custody outside the station and that, even if he had been, he reinitiated contact and knowingly waived his rights. The court also denied his motion for judgment of acquittal, determining that the complainant’s testimony sufficiently established penetration within the charged timeframes.The Supreme Court of Rhode Island 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 reinitiated contact and voluntarily waived his rights. The court also upheld the denial of the motion for judgment of acquittal, finding the evidence was sufficient for a reasonable juror to convict. View "State v. Carreiro" on Justia Law

In this case, a young woman was fatally shot on a Providence street in August 2021 while standing with her boyfriend beside her parked car. The shooting involved a dark sedan that sped by and fired multiple shots, striking the victim. The case remained unsolved for several months until, in December 2021, police stopped a vehicle for traffic violations. The defendant, seated in the rear, was among the occupants. After observing suspicious behavior and a lowered window in inclement weather, officers retraced the vehicle’s route and found a satchel containing a firearm. Forensic testing later matched the gun to shell casings from the murder scene and identified the defendant as the primary DNA contributor. Investigators also obtained incriminating information from an associate of the defendant, including phone communications linking him to the crime.After the defendant was indicted on multiple charges related to the murder and weapon offenses, he filed pretrial motions in Providence County Superior Court to suppress cell phone records obtained via search warrant and DNA evidence from a buccal swab he had consented to during police questioning. Following an evidentiary hearing, the Superior Court denied both motions. At trial, the jury convicted the defendant of most counts, and the trial justice sentenced him to two consecutive life terms plus additional years. The defendant appealed, arguing that the cell phone warrant lacked probable cause and that his consent to the DNA swab was not voluntary.The Supreme Court of Rhode Island reviewed the case and affirmed the Superior Court’s judgment. It held that the affidavit supporting the cell phone warrant, when considered in totality, established probable cause. It further held that the defendant’s consent to the buccal swab was voluntary under the totality of the circumstances. The court found no constitutional violations and upheld the convictions. View "State v. Pinkerton" on Justia Law

In this case, the defendant was previously convicted of second-degree robbery in 1995, stemming from an incident where he feigned injury to gain the trust of a truck driver, then stole the vehicle and some personal items after threatening the victim. He received a sentence of thirty years, with twenty years to serve, ten years suspended, and probation, as well as a consecutive five-year sentence as a habitual offender. Years later, the state alleged that the defendant violated the terms of his probation by failing to keep the peace and be of good behavior, based on recent conduct in which he repeatedly attempted to contact a woman and her mother through phone calls, emails, and visits to her apartment building, causing her significant fear and distress.The Providence County Superior Court held a hearing on the alleged probation violation. After hearing testimony from the complaining witness, her mother, the apartment complex manager, and a police officer, the hearing justice found by a preponderance of the evidence that the defendant had violated his probation. The judge found the witnesses credible and noted the serious impact of the defendant’s conduct on the victim. At sentencing, the court considered the severity of the original crime, the defendant’s background, his potential for rehabilitation, the appropriateness of the punishment, and social deterrence. The court ordered the defendant to serve nine years of the previously suspended ten-year sentence.The Supreme Court of Rhode Island reviewed the case on appeal. The defendant argued that the sentence for the probation violation was excessive and that the court abused its discretion. The Supreme Court held that the Superior Court did not abuse its discretion and appropriately considered both the original offense and the circumstances of the violation. The Supreme Court affirmed the judgment of the Superior Court, upholding the nine-year sentence. View "State v. Peterson" on Justia Law

In the early morning of August 7, 2021, a fatal altercation occurred near West Friendship Street in Providence, Rhode Island. The defendant was present at a nightclub with friends and, after leaving, became involved in a confrontation with several individuals, including the eventual victims, Kenwins Pimental and Mario Diaz. During the altercation, the defendant was physically assaulted, claimed to have been threatened with a knife, and heard threats against his life. After escaping the initial fight, he retrieved a firearm from his car, returned to the scene, and fatally shot Mr. Diaz. He also fired at Mr. Pimental, whom he claimed had fired a gun at him, though evidence did not support that Pimental was armed.The Providence County Superior Court jury acquitted the defendant of charges related to Mr. Pimental’s death but convicted him of the second-degree murder of Mr. Diaz, discharging a firearm while committing a crime of violence, and carrying a firearm without a license. The trial justice declined the defendant's request to instruct the jury on voluntary manslaughter, reasoning that the evidence did not support a heat-of-passion killing provoked by Mr. Diaz. After the verdict, the defendant’s motion for a new trial was denied.On appeal, the Supreme Court of Rhode Island reviewed whether the trial justice erred in refusing to give a voluntary manslaughter instruction. Applying de novo review and viewing the evidence in the light most favorable to the defendant, the Court held that there was not even minimal evidence that Mr. Diaz’s actions constituted adequate provocation or that the defendant acted in the heat of passion such that a voluntary manslaughter instruction was warranted. The judgment of the Superior Court was affirmed. View "State v. Lacourt" on Justia Law