Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the superior court denying Defendant’s motion to reduce a sentence, holding that the trial justice was within his discretion to give and confirm the punishment for Defendant.Defendant was convicted of one count of first-degree child molestation sexual assault. Defendant was originally sentenced to a forty-year term to serve but, after the case was remanded, he was sentenced to life imprisonment. Defendant filed a motion to reduce the sentence, arguing that the life sentence imposed after the second trial was unconstitutional. The trial justice denied the motion. Defendant appealed, arguing that the trial justice abused his discretion by imposing a sentence significantly longer than the sentence imposed after his first conviction. The Supreme Court affirmed, holding that the trial justice properly decided to impose the maximum sentence permitted under the statute in this case and that Defendant failed to demonstrate that the sentence was grossly disparate from other sentences generally imposed for similar offenses. View "State v. Oliveira" on Justia Law

The Supreme Court quashed the order of the superior court finding Defendant guilty of one count of second-degree murder and one count of discharging a firearm while committing a crime of violence, holding that the trial justice erred in granting Defendant’s motion for a new trial by exceeding the scope of this Court’s remand order.After Defendant was convicted, he timely appealed to the Supreme Court but ultimately moved to remand the matter to the superior court for a new trial in light of newly discovered evidence. The Supreme Court granted the motion, and on remand, the trial justice granted Defendant’s motion for a new trial on the ground set forth in his supplemental memoranda - that the trial justice’s jury instructions regarding involuntary manslaughter were improper under State v. Diaz, 46 A.3d 849 (R.I. 2012). The Supreme Court quashed the superior court’s order, holding that the trial justice did not have the authority to consider Defendant’s new-trial arguments based on Diaz, as the arguments fell outside the four corners of the original remand order. View "State v. Arciliares" on Justia Law

The Supreme Court affirmed the order of the family court requiring Defendant to register as a sex offender and denying his motion to waive sex-offender registration and notification pursuant to R.I. Gen. Laws 11-37.1-4(j), holding that there was no error in the proceedings below.On appeal, Defendant argued that the words of section 11-37.1-4(j) that “the conduct of the parties is criminal only because of the age of the victim” plainly applied to his case and that the trial justice should have exercised her discretion under section 11-37.1-4(j) to waive sexual-offender registration. The Supreme Court disagreed, holding (1) the trial justice appropriately determined that the coercion in this case made the conduct at issue criminal, apart from the ages of the victims; and (2) the trial justice appropriately applied the plain language of the statute in determining that she had no discretion in the present case. View "In re B.H." on Justia Law

The Supreme Court affirmed Defendant’s conviction of three counts of second-degree child molestation sexual assault, holding that the trial justice properly admitted testimony regarding previous restraining orders against Defendant and did not err in denying Defendant’s motion for a new trial.Specifically, the Court held (1) the “raise-or-waive” rule precluded Defendant from raising the issue of the admission of the challenged testimony, but even if Defendant had properly preserved the issue on appeal, defense counsel opened the door to the State’s inquiry on the topic during his cross-examination of the witness; and (2) the trial justice did not abuse his discretion in denying Defendant’s motion for a new trial. View "State v. Romero" on Justia Law

The Supreme Court affirmed Defendant’s conviction for carrying a firearm without license and other firearm-related offenses.After Defendant filed his appeal, he filed in the Supreme Court a motion to hold the appeal in abeyance and remanded the matter to the superior court to allow him to seek a new trial based on alleged violations of Brady v. Maryland, 373 U.S. 83 (1963). The Court denied Defendant’s motion to hold the appeal in abeyance but granted the remand motion. A hearing on the alleged Brady violation was held before the same justice of the superior court who presided over Defendant’s trial. The trial justice denied both the Brady-related motion for a new trial and Defendant’s motion to recuse the trial justice. The Supreme Court affirmed, holding that the trial justice did not commit prejudicial error by (1) denying Defendant’s motion to suppress two witnesses’ show-up identifications; (2) admitting the recording of an anonymous 911 call at trial; (3) determining that the state did not commit a Brady violation; and (4) denying Defendant’s motion to recuse the trial justice. View "State v. Washington" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant for the second-degree murder of his girlfriend’s six-year-old son.On appeal, Defendant claimed that he was entitled to a new trial because the trial justice erred in instructing the jury and in admitting certain testimony at trial. The Supreme Court disagreed, holding (1) the trial justice did not err with respect to her instruction on second-degree felony murder; (2) the trial justice did not err with respect to her instruction on causation; and (3) the trial justice did not err in allowing the challenged testimony once Defendant opened the door to its relevancy. View "State v. Pati" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of murder and discharging a firearm while committing a crime of violence, among other crimes.Specifically, the Court held (1) Defendant’s argument that the trial justice erred by allowing a Providence police detective to offer a lay opinion regarding the location of a particular cell phone at a certain point in time was waived because Defendant did not object at trial; and (2) the trial justice did not err by denying Defendant’s motion for a new trial based on the weight of the evidence. View "State v. Moten" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying postconviction relief for Appellant, who challenged the trial court’s acceptance of his nolo contendere plea on a second-degree murder charge.At sentencing, the hearing justice sentenced Appellant to the maximum sentence under the “capped” plea agreement - sixty years’ imprisonment, with twenty years suspended with probation following Appellant’s release. Appellant later filed a pro se application for postconviction relief arguing that he received ineffective assistance of counsel and that the hearing justice failed adequately to explain Appellant’s waiver of constitutional rights when he pled nolo contendere. The superior court denied relief. The Supreme Court affirmed, holding (1) the postconviction relief justice did not overlook or misconceive material evidence, nor did she clearly err in denying Appellant’s postconviction relief application; and (2) any issues related to Shatney v. State, 755 A.2d 130 (R.I. 2000), were cured in this case. View "Navarro v. State" on Justia Law

The Supreme Court vacated Defendant’s convictions on count four, sex trafficking of a minor, in violation of R.I. Gen. Laws 11-67-6, and count six, conspiring to commit the crime of sex trafficking with a minor, holding that a gap in the language of section 11-67-6 rendered it unenforceable.Specifically, the Supreme Court held that the gap in section 11-67-6(b) was a statutory flaw that could not be repaired without the addition of language that criminalizes the conduct described in the statute, which is a task that goes beyond statutory construction. Therefore, the Court held that section 11-67-6 failed to state a crime, and therefore, Defendant’s motion to dismiss counts four and six of the indictment should have been granted. The dissent would affirm the convictions on counts four and six, holding that the statute did not involve the son of legislative commission that required a reversal of Defendant’s conviction because the statute, “for all its lack of absolute perfection in terms of draftsmanship,” sufficed to give fair and adequate notice. View "State v. Maxie" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of felony assault following a jury-waived trial.On appeal, Defendant argued (1) there was sufficient evidence of self-defense to require a finding of not guilty, and (2) the trial justice overlooked material evidence in carrying out his fact-finding function. The Supreme Court disagreed, holding (1) the state successfully rebutted Defendant’s self-defense claim beyond a reasonable doubt; and (2) there was no error in Defendant’s trial. View "State v. Lussier" on Justia Law