Justia Rhode Island Supreme Court Opinion Summaries

Articles Posted in Criminal Law

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The Supreme Court affirmed the judgment of the superior court denying Petitioner's appeal from a decision of a drug court magistrate upholding a determination by the Sex Offender Board of Review classifying Petitioner as a Level II, moderate-risk sex offender, holding that Petitioner's classification was lawful and proper. On appeal, Petitioner argued that the Board violated his rights to due process, to the presumption of innocence, and to be protected from double jeopardy by relying on alleged impermissible hearsay allegations for conduct for which he was eventually acquitted. The Supreme Court affirmed, holding (1) Petitioner failed to demonstrate that his right to procedural due process was violated; (2) the Board considered numerous factors in making its determination; and (3) Petitioner's classification did not violate the Double Jeopardy Clause, and the Board's actions were not in the context of a criminal trial and did not implicate Petitioner's right to a fair trial. View "DiCarlo v. State" on Justia Law

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The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendants on Plaintiff's complaint alleging various claims under, inter alia, the Rhode Island Wiretap Act, state privacy laws, and federal laws after Defendants installed software on Plaintiff's work computer without his knowledge that intercepted Plaintiff's emails and online activities, holding that summary judgment was properly granted. Plaintiff was employed by Defendants before his arrest and eventual conviction for possession of child pornography. Defendant had installed tracking software on Plaintiff's work computer that recorded Plaintiff's online activities and emailed the record to Defendants. The hearing justice found that the intercepted information was disclosed to the police department, leading to Plaintiff's arrest and conviction, that the claims set forth in Plaintiff's complaint were barred by limitations, and that there was no evidence indicating that Defendants had fraudulently concealed the conduct that formed the basis of Plaintiff's computer crime claims. The Supreme Court affirmed, holding (1) Plaintiff's claims were time-barred; (2) Plaintiff could not benefit from the tolling provisions of R.I. Gen. Laws 9-1-20; and (3) the continuing violation doctrine did not apply to Plaintiff's Rhode Island Wiretap Act claim against Defendants. View "Boudreau v. Automatic Temperature Controls, Inc." on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of assault with a dangerous weapon and malicious injury to property, holding that the trial justice did not err in denying Defendant's motion for a new trial. In his motion for a new trial, Defendant argued that the jury's verdict was against the weight of the evidence. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice articulated adequate grounds for denying the motion, carefully reviewed the testimony and weighed the evidence before him, and properly concluded, based on his own credibility determinations, that the weight of the evidence supported guilty verdicts as to both counts. View "State v. Najera" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the judgment of the superior court denying Appellant's application for postconviction relief, holding that the postconviction hearing justice did not err in denying Appellant's application. Twelve years after Appellant entered a nolo contendere plea to the charge of possession of cocaine Appellant filed an application for postconviction relief alleging, among other things, that he received ineffective assistance of counsel because he was not advised of the immigration consequences of his plea. The postconvcition hearing justice denied the application and declined to address the State's issue of laches. The Supreme Court affirmed, holding that Appellant's arguments on appeal lacked merit and that Appellant's petition for postconviction relief could also have been denied based on the doctrine of laches. View "Desamours v. State" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed Defendant's conviction of assault of a police officer, resisting arrest, and disorderly conduct, holding that the trial justice did not err in determining that Defendant had waived his constitutional right to counsel. On appeal, Defendant argued that the trial justice erred in concluding that he made a voluntary, knowing, and intelligent waiver of his constitutional right to counsel. The Supreme Court disagreed, holding that the trial justice did not err in (1) determining that Defendant voluntarily waived his right to counsel prior to trial; and (2) finding that Defendant knowingly and intelligently waived his right to counsel. View "State v. Souto" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree murder by use of a firearm he was not licensed to carry, holding that Defendant was not entitled to relief on any of his allegations of error. Specifically, the Court held (1) the trial justice did not err by denying Defendant's pretrial motion to suppress statements he gave to the police in the first of two interrogations; (2) Defendant failed to show that his trial counsel had an actual conflict of interest throughout her representation of him; (3) Defendant waived his argument that the trial court erred in admitting testimonial and photographic evidence suggesting Defendant's affiliation with known gangs; and (4) Defendant waived direct appellate review of challenged jury instructions. View "State v. Andrade" on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree child molestation sexual assault, holding that the trial justice did not commit clear error in the proceedings below. On appeal, Defendant argued that the trial justice committed clear error by (1) refusing to suppress his statement to the police because the confession was not knowing, intelligent or voluntary, and (2) admitting Defendant's confession into evidence despite Defendant's invocation of his right to remain silent. The Supreme Court affirmed, holding (1) the trial justice did not err in concluding that Defendant's statements to the police were knowing, intelligent, and voluntary; and (2) the trial justice did not err in denying Defendant's motion to suppress his statements to the police during his interrogation. View "State v. Munir" on Justia Law

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The Supreme Court affirmed the order and judgment of the family court finding Respondent delinquent for possession of child pornography, holding that Respondent was not entitled to relief on three of his arguments and that Respondent waived his fourth argument. Specifically, the Court held (1) the family court magistrate did not err in denying Respondent's request for a Franks hearing; (2) the trial justice did not err in determining that the search warrant was supported by probable cause; (3) the trial justice did not err in finding that the police did not need to obtain a new search warrant after the police determined that their original warrant was based on misinformation; and (4) Defendant waived his argument that the trial justice erred by not suppressing Respondent's oral statements to the police. View "In re Austin B." on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of five counts of second-degree sexual assault, holding that the trial justice did not err in denying Defendant's motion for a new trial. On appeal, Defendant argued that the trial justice erred in denying his motion for a new trial because the trial justice overlooked and misconceived the evidence. Specifically, Defendant argued that the trial justice should have rejected the victim's testimony and given it no weight. The Supreme Court disagreed, holding that the trial justice did not overlook or misconceive material evidence and articulated more than adequate grounds for denying Defendant's motion for a new trial. View "State v. Rogers" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the order of the superior court denying Defendant's motion to correct sentence pursuant to Rule 35 of the Superior Court Rules of Criminal Procedure, holding that the trial justice did not err in denying Defendant's motion to correct sentence. In 2006, Defendant was convicted of first- and second-degree child molestation sexual assault. From 2004 until his determination of guilt in 2006, Defendant was on "electronic home confinement" as a condition of bail. Following the completion of his direct and postconviction relief appeals Defendant filed a pro se motion for correction of sentence, arguing that the twenty-four months he spent on home confinement should be credited toward his overall sentence pursuant to R.I. Gen. Laws 12-19-2(a). The trial court denied Defendant's motion. The Supreme Court affirmed, holding (1) the trial justice correctly ruled that Defendant should not be credited with the time he spent on home confinement; (2) Defendant waived his equal protection argument; and (3) the trial justice did not abuse her discretion in denying Defendant's request for counsel in connection with his motion to correct sentence. View "State v. Merida" on Justia Law

Posted in: Criminal Law