Justia Rhode Island Supreme Court Opinion Summaries

Louis Seignious was convicted of first-degree murder, carrying a firearm during the commission of a crime of violence, and domestic breaking and entering. The incident occurred in Westerly, Rhode Island, where Seignious entered the home of his ex-partner, Dionne Johnson, and shot Vincent Sebastian, who was in a relationship with Johnson. The shooting followed a series of confrontations and a video call where Seignious saw Johnson and Sebastian together. Witnesses testified that Seignious entered the home, asked for Sebastian, and then shot him. Sebastian was found dead from a gunshot wound shortly after.In the Superior Court, Seignious was found guilty on all charges by a jury. He filed a motion for a new trial, arguing that the trial justice overlooked material evidence and that there was a lack of physical evidence linking him to the shooting. The trial justice denied the motion, stating that the evidence and witness testimonies were credible and supported the jury's verdict. Seignious was sentenced to life in prison for the murder, with additional consecutive and concurrent sentences for the other charges.The Rhode Island Supreme Court reviewed the case and affirmed the judgment of conviction. The court found no error in the trial justice's denial of the motion for a new trial, noting that the trial justice had properly evaluated the evidence and witness credibility. The court also addressed Seignious's argument regarding the admission of fingerprint testimony without qualifying the witness as an expert. The court concluded that the trial justice did not abuse her discretion, as the testimony was within the common knowledge of an average juror and did not require expert qualification. View "State v. Seignious" on Justia Law

The defendant was convicted of second-degree murder and several firearm offenses after shooting the decedent, Joel Rosario, during a confrontation at a traffic light. The defendant claimed self-defense, stating he felt trapped and threatened by Rosario and others who surrounded his vehicle. The defendant testified that he saw Rosario with a firearm and fired a single shot in fear for his life.The Superior Court found the defendant guilty on all counts and sentenced him to life in prison for second-degree murder, a consecutive life sentence for discharging a firearm during a crime of violence, and additional sentences for other firearm offenses. The defendant appealed, arguing that the trial justice erred by not instructing the jury on the lesser-included offense of voluntary manslaughter, excluding testimony about a threat made by the decedent, excluding testimony about a prior violent altercation, and determining that a social media post depicting the decedent with a firearm was inadmissible.The Rhode Island Supreme Court reviewed the case and found that the trial justice committed reversible error by not instructing the jury on voluntary manslaughter, as there was sufficient evidence to support such a charge. The court also held that the exclusion of the defendant’s grandfather’s testimony about a threat to kill the defendant was reversible error, as it was relevant to the defendant’s state of mind and claim of self-defense. However, the exclusion of testimony about the 2018 pistol-whipping incident was deemed harmless error. The court vacated the judgment of the Superior Court and remanded the case for a new trial on the charge of second-degree murder and the lesser-included offense of manslaughter. View "State v. Esdel" on Justia Law

The defendant was convicted by a jury in the Superior Court on one count of first-degree child molestation, three counts of second-degree child molestation, and one count of simple assault and battery. The charges stemmed from allegations made by the complaining witness, a minor, who claimed that the defendant, her mother's boyfriend, had sexually abused her over several years. The witness wrote a letter to her mother detailing the abuse and later provided a handwritten statement to the police.In the Superior Court, the trial justice admitted the letter as nonhearsay under Rule 801(d)(1)(B) of the Rhode Island Rules of Evidence, reasoning it was offered to rebut an implied charge of recent fabrication. The trial justice also admitted the handwritten statement to the police as an excited utterance under Rule 803(2). The defendant was sentenced to life imprisonment for the first-degree child molestation count, thirty years for each of the second-degree child molestation counts, and one year for the simple assault and battery count, all to run concurrently. The defendant appealed, arguing that the trial justice erred in admitting the out-of-court statements and excluding video evidence of the witness's demeanor at the police station.The Rhode Island Supreme Court reviewed the case and found that the trial justice erred in admitting the letter as nonhearsay because the defense did not allege recent fabrication. The court also determined that the handwritten statement did not qualify as an excited utterance since it was made months after the alleged events. Additionally, the court held that the exclusion of the video evidence was within the trial justice's discretion. Concluding that the erroneous admission of the statements was not harmless and likely contributed to the conviction, the Supreme Court vacated the judgment of conviction and remanded the case for a new trial. View "State v. Aponte" on Justia Law

The defendant, Jason Ortiz, was charged with several criminal counts, including carrying a pistol without a license, domestic assault, resisting arrest, and disorderly conduct. The charges stemmed from an incident in which Ortiz was apprehended by police after a domestic dispute. The police found a pistol in the vicinity of Ortiz's arrest, and DNA evidence linked Ortiz to the weapon. Ortiz was nineteen years old and a resident of Massachusetts at the time of his arrest.In the Superior Court for Providence County, Ortiz filed a motion to dismiss the charge of carrying a pistol without a license, arguing that the Rhode Island statute requiring a license to carry a pistol violated his Second Amendment rights. The state objected, arguing that Ortiz lacked standing to challenge the statute because he had never applied for a license and therefore had not been denied one. The trial justice denied Ortiz's motion to dismiss, finding that Ortiz lacked standing to challenge the statute and that the statute was reasonably adopted to address the government's interest in reducing gun violence. After a bench trial, Ortiz was found guilty of carrying a pistol without a license and sentenced to five years imprisonment, with eighteen months to serve and the balance of the sentence suspended, with probation.On appeal to the Supreme Court of Rhode Island, Ortiz argued that the trial justice erred in denying his motion to dismiss. He contended that the licensing statute violated his Second Amendment rights and that he had standing to challenge the statute because he was being punished for violating it. The state argued that Ortiz lacked standing to challenge the statute because he had not applied for a license. The Supreme Court affirmed the judgment of the Superior Court, holding that Ortiz lacked standing to challenge the licensing statute because he had not applied for a license and would not have qualified for one had he applied due to his age and residency. The court declined to reach Ortiz's arguments regarding the constitutionality of the licensing statute. View "State v. Ortiz" on Justia Law

The case involves Napoleao Pires, who was convicted for carrying a firearm without a license and possession of a controlled substance. The conviction was based on evidence obtained when a police officer, responding to a dispatch, stopped and searched Pires. The dispatch reported a man matching Pires' description walking around with a gun. Upon arrival, the officer did not observe any criminal activity or see a gun, but stopped Pires based on the dispatch information. Pires challenged the trial justice’s decision to deny his motion to suppress the evidence, arguing that the seizure violated his constitutional rights under the Fourth Amendment.The Superior Court held a hearing on the motion to suppress and concluded that the gun and cocaine had been lawfully seized. The court found that the officer's thirty years of experience, the dispatch sending him to a high-crime area, Pires' match to the dispatch description, Pires' noncompliance to the officer’s commands, and Pires' pivot to reach for his waistband amounted to the level of reasonable suspicion required to justify the warrantless stop.The Supreme Court of Rhode Island reversed the decision on the motion to suppress and vacated the judgment of conviction. The court held that Pires was seized the moment he complied with the officer’s order to raise his hands. The court found that the state failed to submit adequate evidence to show that reasonable suspicion existed at the inception of Pires' encounter with the officer. The court concluded that Pires' Fourth Amendment rights were violated because the state failed to submit adequate evidence to show that reasonable suspicion existed at the inception of his encounter with the officer. View "State v. Pires" on Justia Law

The case involves Miguel Tebalan Rivera who was convicted of second-degree murder and commission of a crime of violence while in possession of a knife with a blade longer than three inches. Rivera filed an application for postconviction relief, arguing that his trial counsel was ineffective for failing to advise him that if he did not testify, he would be convicted of second-degree murder.The trial court granted Rivera's application for postconviction relief, finding that his trial counsel's performance was deficient and that this deficiency prejudiced Rivera's defense. The court found that Rivera's trial counsel failed to advise him that if he did not testify, he would be convicted of second-degree murder. The court also found that Rivera's trial counsel failed to recognize and explain to Rivera that if he did not testify, he would be waiving his right to present his claim of self-defense.The State of Rhode Island appealed the trial court's decision, arguing that the trial court erred in finding that Rivera's trial counsel was ineffective. The Supreme Court of Rhode Island affirmed the trial court's decision, holding that Rivera's trial counsel's performance was deficient and that this deficiency prejudiced Rivera's defense. The court found that Rivera's trial counsel failed to advise him that if he did not testify, he would be convicted of second-degree murder. The court also found that Rivera's trial counsel failed to recognize and explain to Rivera that if he did not testify, he would be waiving his right to present his claim of self-defense. View "Rivera v. State of Rhode Island" on Justia Law

The defendant, Lydia Alicea, was charged with violating a law between February 18, 2017, and August 1, 2017. On June 19, 2020, she pleaded nolo contendere and was given a two-year deferred sentence and ordered to pay $1,800 in restitution. Alicea entered into a deferred-sentence agreement with the Office of the Attorney General, agreeing to the terms of her sentence, including the payment of restitution. However, she failed to pay the court-ordered restitution in accordance with the agreement. Almost two years later, the state filed a notice of violation and Alicea appeared before a Superior Court magistrate.The magistrate inquired whether Alicea had the ability to pay the outstanding balance before the expiration of her sentence. Alicea represented that she could satisfy the outstanding amount before the deferred-sentence agreement expired, as she had recently become employed. However, she failed to make any payments towards her outstanding balance. The court scheduled a violation hearing based on Alicea’s failure to comply with the restitution obligation of her deferred-sentence agreement. At the hearing, Alicea submitted a hand-written financial statement in support of her argument that she was unable to pay restitution. The court found Alicea in violation of the deferred-sentence agreement and imposed a sentence of three years of probation and ordered her to pay $36.15 in monthly installments toward the outstanding restitution amount.Alicea appealed the magistrate’s decision to a justice of the Superior Court. The trial justice denied the appeal and the restitution payments were set to resume. Alicea then appealed to the Supreme Court of Rhode Island. The Supreme Court vacated the judgment of the Superior Court and remanded for further proceedings, stating that Alicea was entitled to an evidentiary hearing regarding her ability to pay before a sentence could be imposed. View "State v. Alicea" on Justia Law

The case involves Nicholas Finnigan, who was convicted of one count of second-degree child molestation following a jury-waived trial in the Superior Court. The incident allegedly occurred in February 2012, when the victim, R.B., was under fourteen years old. Finnigan was sentenced to ten years, with fifty-four months to serve and the remainder suspended, and ten years of probation. Finnigan appealed the conviction, arguing that the trial justice overlooked or misconceived material evidence.The Superior Court heard testimonies from several witnesses, including the victim, R.B., who testified that Finnigan touched her inappropriately while she was sleeping in her bedroom. Other witnesses corroborated aspects of R.B.'s account, including her mother and aunt who testified that they saw Finnigan leaving R.B.'s room on the night of the incident. Finnigan denied the allegations and claimed he never entered R.B.'s bedroom on the night in question. The trial justice found R.B. to be a credible witness and concluded that Finnigan was guilty of second-degree child molestation.The case was brought before the Supreme Court of Rhode Island. Finnigan argued that the trial justice overlooked or misconceived material testimony about the night of the alleged incident and failed to properly weigh the conflicting testimony regarding the actual date of the alleged incident. The Supreme Court, after reviewing the record, concluded that sufficient competent evidence existed to support the trial justice’s general finding of guilt beyond a reasonable doubt on the charge of second-degree child molestation. The court affirmed the judgment of the Superior Court, stating that the trial justice did not misconceive or overlook the inconsistent testimony about the date of the incident. The court also noted that there is no requirement of independent corroboration for sex-offense cases. View "State v. Finnigan" on Justia Law

Edward Mather, the defendant, was charged with multiple counts of domestic assault, vandalism, and violation of a no-contact order. Following his arraignment, he was ordered to undergo a psychiatric evaluation to determine his competency to stand trial. The evaluation concluded that Mather was incompetent to stand trial and required hospitalization. Subsequently, he was committed to an outpatient facility, LaBelle House Group Home, under the custody of the Department of Behavioral Healthcare, Developmental Disabilities and Hospitals (BHDDH).The Superior Court held a commitment hearing and based on a report from BHDDH, found Mather remained incompetent to stand trial. The court ordered Mather to remain committed to BHDDH's custody but allowed him to be placed in an outpatient facility without endangering himself or others. The court also ordered that if Mather violated the conditions of the order, engaged in threatening or aggressive behavior, or required hospitalization, he should be immediately returned to Eleanor Slater Hospital.Mather filed a petition to discharge from the detention order of commitment in both of his pending criminal matters. He argued that his continued institutionalization at the outpatient facility restricted his liberty and violated due process. The trial justice denied Mather's petitions, reasoning that his commitment to the outpatient facility did not constitute "detention" pursuant to the relevant statute. Mather sought review of the decision, and the Supreme Court of Rhode Island granted the petitions, consolidated the cases for review, and issued the writ.The Supreme Court of Rhode Island quashed the orders of the Superior Court and remanded the matter for further proceedings. The court held that the trial justice committed a reversible error of law when he denied the petitions to discharge from detention orders of commitment. The court concluded that Mather's continued commitment no longer bore a reasonable relationship to the purpose of his commitment under the relevant statute. The court held that where a defendant is found to be incompetent to stand trial and competency is nonrestorable prior to the statutory dismissal period, the defendant is entitled to be discharged from detention under the order of commitment thirty days thereafter. View "State v. Mather" on Justia Law

This case involves four individuals, Joao Neves, Keith Nunes, Pablo Ortega, and Mario Monteiro, who were convicted of various crimes in Rhode Island and were serving multiple sentences, including life sentences. The issue at hand is the interpretation of a Rhode Island statute, G.L. 1956 § 13-8-13(e), which was enacted in 2021 and provides that any person sentenced for any offense committed prior to their twenty-second birthday, other than a person serving life without parole, shall be eligible for parole review after serving no fewer than twenty years' imprisonment.The state argued that the statute applies only to individuals serving a single sentence and does not require the aggregation of multiple sentences for parole eligibility. The respondents, on the other hand, argued that the statute applies to "any offense," and thus requires the aggregation of multiple sentences, including consecutive sentences, for parole eligibility.The trial justice agreed with the respondents and ordered that each respondent be immediately released on parole. The state appealed, arguing that the trial justice's interpretation of the statute violated the separation-of-powers doctrine by modifying judicial sentences.The Supreme Court of Rhode Island held that the statute mandates the aggregation of a qualified offender’s sentences, including consecutive sentences, for parole eligibility. The court also concluded that the statute, as interpreted, does not violate the separation-of-powers doctrine. However, the court found that the trial justice erred in ordering each respondent to be immediately released on parole, as the statute only provides a qualified offender the opportunity to appear before the parole board, not the right to be paroled. The court affirmed in part and vacated in part the judgments of the lower court, and remanded the cases to the parole board for further proceedings. View "Neves v. State of Rhode Island" on Justia Law