Justia Rhode Island Supreme Court Opinion Summaries

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

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

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

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

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

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

The Supreme Court affirmed Defendant's conviction of two counts of first degree robbery and one count of conspiracy to commit robbery, holding that the admission of an out-of-court statement made by an alleged coconspirator who did not appear at Defendant's trial, was harmless beyond a reasonable doubt.While the sole issue on appeal was whether Defendant's Sixth Amendment confrontation rights were violatedl. The Court held (1) this Court assumes, without deciding, that a Confrontation Clause objection was properly articulated; and (2) because the remaining evidence was sufficiently compelling to support the jury's finding of guilty, the admission of the coconspirator's out-of-court declaration was harmless beyond a reasonable doubt. View "State v. Sanchez" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Defendant's motion for a new trial after convicting Defendant of of assault and battery resulting in serious bodily injury and possession of a knife with a blade of more than three inches, 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 trial justice overlooked and misconceived material evidence when he agreed with the jury's verdict because the trial justice did not take into account that Defendant had to appreciate that he knowingly had an opportunity to retreat in safety. The Supreme Court disagreed, holding that the trial justice more than adequately performed his role under each step of the analysis of Defendant's motion for a new trial. View "State v. Guerrero" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree murder, holding that Defendant waived his argument that the trial justice erred when she failed to instruct the jury on the lesser-included offense of voluntary manslaughter and that the trial justice did not err in refusing to grant a mistrial.Specifically, the Court held (1) Defendant's contention that the trial judge erred in failing to give the jury an instruction on voluntary manslaughter and instead giving an involuntary manslaughter instruction was not properly preserved for appellate review; (2) the trial justice did not err in refusing to declare a mistrial on what Defendant characterized as the prosecutor's "wholly improper" statements made during closing argument because the court's cautionary instruction cured the prejudice created by the prosecutor's comments labeling Defendant as a scam artist, liar, and thief. View "State v. Lastarza" on Justia Law

The Supreme Court affirmed Defendant's conviction of four counts of first-degree child molestation sexual assault, holding that Defendant was not entitled to a new trial based on any of his arguments on appeal.Specifically, the Court held (1) the trial justice did not err when he accepted a jury waiver form that Defendant had signed outside the presence of the trial justice; (2) Defendant's colloquy with the trial justice demonstrated that Defendant knowingly, intelligently, and voluntarily waived his right to a jury trial; and (3) the trial justice adequately explained the differences between a jury trial and a bench trial. View "State v. Morais" on Justia Law