Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court vacated the decision of the superior court granting Defendant’s motion to suppress statements he made to a Massachusetts Department of Children and Families investigator on grounds that the investigator’s failure to advise Defendant of his right to counsel rendered the statements involuntary.Defendant was indicted by a grand jury on four counts of child molestation. The Supreme Court vacated the decision of the hearing justice granting Defendant’s motion to suppress, holding that, under the circumstances of this case, Defendant’s statements were voluntary, and the motion to suppress should have been denied. View "State v. Gouin" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Petitioner’s application for postconviction relief, in which Petitioner claimed that he received ineffective assistance of trial counsel. The Court held (1) Petitioner’s trial counsel was not ineffective for failing to utilize an expert witness on false confessions; (2) the trial justice did not clearly err in refusing to approve funding for the hiring of an expert witness on false confessions in this postconviction relief action; and (3) trial counsel was not ineffective for failing to file a motion to recuse the justice during the trial, and the trial justice did not err in not recusing himself from hearing the instant application for postconviction relief. View "Barros v. State" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Petitioner’s application for postconviction relief, in which Petitioner claimed that he received ineffective assistance of trial counsel. The Court held (1) Petitioner’s trial counsel was not ineffective for failing to utilize an expert witness on false confessions; (2) the trial justice did not clearly err in refusing to approve funding for the hiring of an expert witness on false confessions in this postconviction relief action; and (3) trial counsel was not ineffective for failing to file a motion to recuse the justice during the trial, and the trial justice did not err in not recusing himself from hearing the instant application for postconviction relief. View "Barros v. State" on Justia Law

The Supreme Court affirmed the trial court’s judgment convicting Defendant of second-degree murder, discharging a weapon while committing a crime of violence, and possession of a firearm, having previously been convicted of a felony. The Court held (1) the trial justice properly denied Defendant’s Watson claims as to two prospective jurors; (2) the trial justice did not improperly restrict the cross-examination of a witness about a firearm the witness saw two days before the homicide; (3) the trial justice did not err when she denied Defendant’s motion to pass the case after a spectator’s emotional outburst during the defense’s opening statement; and (4) the trial justice did not err by denying Defendant’s motion for a new trial. View "State v. Porter" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of two counts of first-degree child molestation and one count of second-degree child molestation. The court held (1) the trial justice did not abuse his discretion by failing to exclude certain testimony as a result of the State’s violation of Rule 16 of the Superior Court Rules of Criminal Procedure; (2) the trial judge did not err by admitting the testimony at issue pursuant to Rule 404(b) of the Rhode Island Rules of Evidence; (3) even if the testimony was admissible under Rule 404(b), the trial judge did not err in admitting the testimony under Rule 403 of the Rhode Island Rules of Evidence; (4) the trial judge did not overlook or misconceive material evidence in analyzing Defendant’s motion for new trial; and (5) the trial justice did not err in denying Defendant’s motion for judgment of acquittal. View "State v. Rainey" on Justia Law

Collateral estoppel is not applicable to issues determined in the Rhode Island Traffic Tribunal when the issues are “only a small part of a larger, ongoing criminal investigation.”Defendant in this case was cited in the Rhode Island Traffic Tribunal with the civil violation of reasonable and prudent speeds. Defendant was also charged criminally in Superior Court with driving under the influence, serious bodily injury resulting and reckless driving. Defendant sought to dismiss his criminal charges, arguing that the Traffic Tribunal magistrate determined that he was not operating the vehicle, and therefore, the issue could not be relitigated based on collateral estoppel. The Superior Court magistrate granted the motion to dismiss. A Superior Court justice reversed the dismissal. The Supreme Court affirmed, holding that in matters that are only a small part of a larger, ongoing criminal investigation, the Traffic Tribunal’s process is insufficient to estop a later criminal proceeding. View "State v. Minior" on Justia Law

The Supreme Court affirmed the decision of the superior court adjudging Defendant to have violated the terms and conditions of his probation and executing eighteen years of a twenty-year suspended sentence. On appeal, Defendant argued that the hearing justice “went far beyond the scope of the probation violated hearing in deciding that [Defendant] had committed first degree sexual assault by a fair preponderance of the evidence.” The Supreme Court disagreed, holding that the hearing justice did not err in finding that Defendant had violated the terms and conditions of his probation. View "State v. Simpson" on Justia Law

The Supreme Court affirmed the judgment of the superior court finding that Defendant violated the terms and conditions of his probation and ordering him to serve at the Adult Correctional Institutions (ACI) six of the seven years of his previously suspended sentence. Defendant appealed, arguing that the hearing justice acted arbitrarily and capriciously in adjudicating him to be a probation violator because the record in this case did not substantiate the finding that he failed to keep the peace or remain on good behavior when he made certain statements in the course of telephone calls from prison, where he had been detained. The Supreme Court reversed, holding that the hearing justice’s decision adjudging Defendant to be a probation violator was neither arbitrary nor capricious. View "State v. Mosley" on Justia Law

From this point forward, Shatney v. State, 755 A.2d 130 (R.I. 2000), shall be deemed abrogated and inapplicable in any case involving both an initial application for postconviction relief and an applicant who has been sentenced to life without the possibility of parole.Appellant was convicted of first-degree murder and sentenced to life without the possibility of parole. The Supreme Court affirmed. This appeal concerned Appellant’s second amended application for postconviction relief. The hearing justice dismissed Appellant’s application after a hearing. The Supreme Court vacated the judgment of the superior court, holding (1) Shatney and Tassone v. State, 42 A.3d 1277 (R.I. 2012) are inconsistent with each other and may not properly be permitted to coexist as it relates to life without parole cases; and (2) Appellant was not provided with the evidentiary hearing to which he was entitled pursuant to Tassone. View "Motyka v. State" on Justia Law

The Supreme Court affirmed the hearing justice’s denial of Appellant’s application for postconviction relief seeking leave to withdraw his guilty pleas to breaking and entering and larceny charges. The breaking and entering and larceny pleas were entered in 1994, and Appellant had since served his entire sentence with respect to those cases. The Supreme Court concluded that the relief Appellant sought was the vacating of his 2008 guilty plea to second-degree murder and the dismissal of his 2004 murder indictment. The Supreme Court held (1) the 2004 murder charge and Appellant’s eventual guilty plea were not properly before the court; and (2) Appellant’s contention of ineffective assistance of counsel was not properly before the court. View "Burke v. State" on Justia Law