Justia Rhode Island Supreme Court Opinion Summaries

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

A young woman, who had been in the custody of the Rhode Island Department of Children, Youth and Families, stayed at the defendant’s apartment after leaving various homes to avoid group placement. She testified that while staying with the defendant, a family friend, he sexually assaulted her at gunpoint in his car after they left the apartment together at night. Following the assault, the complainant did not immediately leave the apartment due to fear for her safety. The next morning, she confided in the defendant’s roommate, who became emotional and told her she needed to leave. She subsequently contacted her mother and was picked up by her mother, cousin, and boyfriend. She did not initially report the assault to authorities, fearing placement in a group home, but disclosed the incident to police nearly two years later.The case proceeded in the Providence County Superior Court, where a grand jury indicted the defendant for first-degree sexual assault. At trial, the complainant’s account was central to the prosecution. The defendant objected to the admission of the roommate’s statements to the complainant, arguing that they constituted inadmissible hearsay. The trial justice overruled these objections, and the jury found the defendant guilty. The defendant was sentenced to fifty years, with twenty-five to serve and twenty-five suspended with probation.On appeal to the Supreme Court of Rhode Island, the defendant argued that the admission of the roommate’s statements was reversible error. The Supreme Court held that the statements were not hearsay because they were not offered for their truth, but rather to explain the complainant’s subsequent actions in leaving the apartment. The Court found no abuse of discretion by the trial justice and affirmed the conviction. The case was remanded to the Superior Court. View "State v. Gilbert" on Justia Law

The case involves a fatal shooting that occurred during an attempted marijuana purchase in Providence, Rhode Island. The defendant accompanied a friend to buy marijuana from the decedent, who required purchasers to provide identification. The defendant entered the decedent’s car with a firearm, allegedly for protection, and a struggle ensued inside the vehicle. During the altercation, the firearm discharged, resulting in the decedent’s death. The defendant claimed that the shooting was accidental and that he acted in fear during the struggle. After the incident, the defendant returned to his friend’s car and left the scene.The Superior Court conducted a jury trial in which the defendant was convicted of second-degree murder, discharging a firearm while committing a crime of violence, and carrying a pistol without a license. The defendant moved for a new trial, arguing that the verdict was against the weight of the evidence and that the trial justice made errors, including factual misstatements about his role in the events and reliance on facts not in evidence. The trial justice denied the motion, finding the jury’s verdict justified and crediting prosecution witnesses, but mistakenly referred to the defendant as a drug dealer and seller, which was not supported by the record, and referenced evidence not presented at trial.The Supreme Court of Rhode Island reviewed the appeal. It found no error in the exclusion of certain testimony under the State v. Harnois line of cases. However, the Supreme Court determined that the trial justice’s mischaracterization of the defendant’s role and reliance on facts outside the evidence constituted clear error. The Supreme Court vacated the order denying the motion for a new trial and remanded the case for a new hearing on the motion for a new trial in the Superior Court. View "State v. Garcia" on Justia Law

In the early hours of January 24, 2022, the defendant fatally shot one individual and seriously injured another outside a nightclub in Pawtucket, Rhode Island. He did not dispute that he fired the shots, but claimed at trial that he acted in defense of his cousins, whom he believed were in imminent danger after a physical altercation. The incident was captured on video, which at certain points contradicted the defendant’s account. During the trial, the main factual dispute centered on whether the defendant’s use of force was justified under the defense of others doctrine.The case was tried in the Providence County Superior Court. The jury found the defendant guilty of second-degree murder, discharging a firearm during a violent crime resulting in death, and firearm possession offenses, but acquitted him of charges related to the shooting of the second individual. The trial justice sentenced the defendant to a lengthy period of incarceration. During the trial, improper questions from the prosecutor regarding the defendant’s post-arrest silence were objected to and sustained, with the trial justice issuing cautionary instructions to the jury and ultimately denying the defense’s motion for a mistrial.On appeal, the Supreme Court of Rhode Island reviewed whether the trial justice erred in denying a mistrial after the prosecution impermissibly questioned the defendant about his exercise of the right to remain silent. The Supreme Court held that the prosecutor’s questions violated the defendant’s due process rights, as such use of post-arrest silence for impeachment is fundamentally unfair. The Court found that the cautionary instructions did not cure the prejudice resulting from these questions and concluded that a mistrial was warranted. Accordingly, the Supreme Court vacated the conviction and remanded the case for further proceedings. View "State v. Baker" on Justia Law

A woman was discovered dead and buried in a shallow grave on Crescent Beach in Riverside, Rhode Island, in June 1994. The investigation quickly focused on Gary Tassone after the victim’s estranged husband reported her missing and provided information connecting her to Tassone. Detectives interviewed Tassone, who gave several statements to police—initially denying, then repeatedly revising, his account of the night, ultimately admitting to being with the victim, striking her with a shovel, and leading police to evidence he claimed to have discarded. Physical evidence, including sand and personal items, further linked him to the crime scene. Tassone was indicted and charged with first-degree murder.The Superior Court held a suppression hearing and denied Tassone’s motion to suppress his confessions, finding he was not in custody at the outset and that his statements were voluntary, knowing, and intelligent waivers of his rights. At trial, the jury convicted Tassone of first-degree murder, finding the crime involved torture or aggravated battery, and he was sentenced to life without parole. The conviction was affirmed on direct appeal. Tassone later sought postconviction relief in the Superior Court, asserting ineffective assistance of counsel based on various alleged failures by trial counsel. After an evidentiary hearing, the Superior Court denied his application.On review, the Supreme Court of Rhode Island affirmed the Superior Court’s denial of postconviction relief. The Court held that Tassone failed to demonstrate that his counsel’s performance was objectively unreasonable or that any alleged deficiencies prejudiced his defense, given the overwhelming evidence of guilt, including his own detailed confessions and corroborating physical evidence. As a result, the judgment was affirmed. View "Tassone v. State of Rhode Island" on Justia Law

The defendant was involved in a fatal shooting that followed a drug transaction in Providence, Rhode Island, on April 22, 2021. He was a longtime drug dealer and, on the night in question, sold cocaine to a woman with her boyfriend (the decedent) present. During and after the transaction, the decedent became agitated, shouting threats at both the defendant and the woman. The confrontation escalated when the decedent approached the defendant’s car, yelled additional threats, and appeared to hold an object the defendant believed to be a firearm. The defendant then shot the decedent in the chest, fled the scene, and later disposed of evidence.The case was tried in the Providence County Superior Court. Before trial, the defendant pleaded guilty to two firearm-related charges that were not presented to the jury. At trial, he asserted self-defense and requested that the jury be instructed on the lesser-included offense of voluntary manslaughter, arguing that the evidence supported a finding that he acted in the heat of passion due to adequate provocation. The trial justice denied this request, finding the defendant’s demeanor and testimony showed he was calm and not provoked to the extent required by law. The jury convicted the defendant of second-degree murder and discharging a firearm during a crime of violence. The trial justice imposed consecutive life sentences and additional terms for the firearm charges.The Supreme Court of Rhode Island reviewed the case. It held that there was insufficient evidence to warrant a voluntary manslaughter instruction because the facts did not support finding adequate provocation or sudden heat of passion. The court further declined to consider the defendant’s argument regarding the excessiveness of his sentence because he failed to seek sentence revision under Rule 35 in the Superior Court. The Supreme Court affirmed the judgment of conviction. View "State v. Xaykosy" on Justia Law

Two individuals, Nazaski Carrasco-Smith and Devin Delacruz, were shot while sitting in a vehicle in Providence, Rhode Island, on December 4, 2020. Carrasco-Smith survived; Delacruz did not. The investigation led police to a rented Nissan Altima and uncovered connections between the defendant, his girlfriend, and others through surveillance footage, GPS tracking, and extensive cell phone data analysis. Police also discovered a GPS tracker on Carrasco-Smith’s vehicle and recovered incriminating text messages between the defendant and his girlfriend, some of which contained accusations related to the murder.After a grand jury indictment, the case proceeded to trial in the Providence County Superior Court. The state presented forensic and digital evidence as well as expert testimony on local gang rivalries, suggesting a motive. During the trial, the prosecution introduced text messages from the defendant’s girlfriend accusing him of involvement in the murder. The defendant moved to exclude these messages, arguing they were hearsay and unfairly prejudicial. The trial justice denied the motion, admitted the messages, and issued cautionary instructions to the jury. The jury convicted the defendant on all counts, including first-degree murder and multiple firearm offenses. The defendant moved for a new trial, which was denied, and was sentenced to consecutive life terms and additional concurrent sentences.The Supreme Court of Rhode Island reviewed the case. It held that the trial justice abused her discretion by admitting the girlfriend’s accusatory text messages, finding that their probative value was substantially outweighed by their prejudicial effect under Rule 403 of the Rhode Island Rules of Evidence. The court determined that the cautionary instructions given did not cure the prejudice and that the error was not harmless in light of the prosecution’s emphasis on the messages. The court vacated the conviction and remanded for a new trial. View "State v. Chandler" on Justia Law

The case involves a defendant who was charged with several drug-related offenses in two separate incidents, each involving multiple codefendants. The same attorney, David A. Cooper, entered his appearance to represent the defendant in both matters. During bail hearings in the Rhode Island Superior Court, the trial justice expressed concern about a potential conflict of interest because Attorney Cooper had previously represented one of the codefendants in a related matter. The trial justice questioned both the attorney and the defendant about this issue, and the defendant indicated that she understood the situation and wanted to continue with her chosen counsel, expressing her willingness to waive any potential conflict.Despite the defendant’s statements, the Superior Court trial justice removed Attorney Cooper as counsel, citing a “strong potential for conflict,” even though there was no actual conflict at the time. The court’s order was based on the attorney’s prior representation of a codefendant and the possibility that interests might diverge in the future, and a written waiver from the codefendant was obtained, while the defendant’s waiver was made orally in open court.The Supreme Court of Rhode Island reviewed the matter on writs of certiorari. The Supreme Court concluded that, although trial courts have discretion to remove counsel when there is an actual or serious potential conflict of interest, such a removal must be supported by a substantial showing that the likelihood and dimensions of the feared conflict are significant. The Supreme Court held that, in this case, the record did not support a sufficient showing of a substantial potential conflict to justify overriding the defendant’s chosen counsel at that time. Accordingly, the Supreme Court quashed the Superior Court’s orders removing Attorney Cooper as counsel and remanded the case. View "Viera v. State" on Justia Law