Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the superior court denying Defendant’s motion for a new trial and her request to proceed pro se.Defendant was found guilty of one count of simple assault following a jury trial. After Defendant’s motion for a new trial was denied, Defendant appealed. The Supreme Court affirmed, holding (1) the evidence was sufficient to support Defendant’s conviction, and therefore, the trial justice did not err in denying Defendant’s motion for a new trial; and (2) the trial justice did not err in concluding that Defendant had not made the “requisite intelligent and knowing decision to discharge counsel” and in therefore denying Defendant’s request to discharge her attorneys. View "State v. Withers" on Justia Law

The Supreme Court affirmed the judgment of the superior court finding that Defendant violated the terms of his probation, sentencing him to serve sixteen years in prison, and denying Defendant’s motion for reconsideration. The Supreme Court held (1) the hearing justice did not act arbitrarily or capriciously in finding a witness to be a credible witness at the probation-violation hearing; (2) the hearing justice did not err in finding that Defendant did not keep the peace or act with good behavior and in thus denying Defendant’s motion for reconsideration; and (3) the hearing justice did not abuse his discretion in executing the remaining sixteen years of Defendant’s suspended sentence. View "Neufville v. State" on Justia Law

In this criminal case in which Defendant was convicted of several crimes, the Supreme Court affirmed the judgment of the superior court denying Defendant’s motion for judgment of acquittal on the count of conspiracy to commit the crime of breaking and entering and refusing to grant a new trial on the breaking and entering a dwelling without consent charge. The court held (1) Defendant’s motion for a judgment of acquittal on the crime of conspiracy was properly denied because abundant and direct evidence was introduced from which a fact-finder could find that Defendant agreed to enter the dwelling; and (2) Defendant did not properly raise his argument before the trial justice regarding the breaking and entering charge, and therefore, this issue was waived. View "State v. Huntley" on Justia Law

A passenger in a moving vehicle who forcibly seizes the steering wheel has exercised sufficient control of the vehicle to be deemed a “driver” or “operator” under the reach of chapter 27 of title 31, and therefore, the terms “operating” or “driving” under R.I. Gen. Laws 31-27-1.2, 31-27-2.6 and 31-11-18 can encompass a passenger in a moving motor vehicle who seizes the wheel from the driver and steers the vehicle.The Supreme Court vacated the judgment of the superior court granting a motion to dismiss several counts set forth in a criminal information against Defendant for lack of probable cause pursuant to Rule 9.1 of the superior court rules of criminal procedure. Specifically, the trial justice declared that Defendant could not have violated the statutes at issue because Defendant - a back-seat passenger - was not operating or driving the motor vehicle when he grabbed the steering wheel and turned it, causing the vehicle to roll over. The Supreme Court held (1) by steering the direction of a moving vehicle, Defendant placed himself in the realm of the vehicle’s operator; and (2) this conduct can support a prosecution for violating sections 31-27-1.2, 31-27-2.6 and 31-11-18. View "State v. Peters" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree murder. The court held (1) even though Defendant’s trial commenced after the 180 days required by the Interstate Agreement on Detainers Act (IAD), Defendant’s federal sentence’s expiration nullified any rights he had under the IAD, and the delay in bringing the case to trial was a result of Defendant’s own pretrial motions; (2) the trial justice did not err in denying Defendant’s motions to suppress the seizure of his cell phone and the records of that cell phone, as well as other evidence retrieved from his apartment; (3) Defendant’s argument that the trial justice erred in allowing the admission of statements he made while he was in the hospital was waived; and (4) the sentence imposed on Defendant was not unduly harsh or unwarranted. View "State v. Tejeda" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree robbery following a jury-waived trial. On appeal, Defendant argued that the trial justice misconstrued the complainant’s testimony as to who confronted him and also erred in relying on a witness’s prior witness statements where her inability to read rendered her unable to effectively acknowledge her prior statements. The Supreme Court disagreed, holding (1) the trial justice, in summarizing the complainant’s testimony, accurately recounted it; and (2) because the witness was capable of recognizing her prior statements and could do so through the means the prosecutor used, the trial justice did not misconceive or overlook evidence. View "State v. Padilla" on Justia Law

The Supreme Court affirmed Defendant’s conviction of first-degree murder, discharging a firearm during a crime of violence, resulting in a death, and other crimes. On appeal, Defendant argued that the trial justice erred when he (1) denied Defendant’s request to order the State to produce the investigative notes of a detective with the Providence Police Department because Defendant was entitled to the notes pursuant to Rule 16 of the Superior Court Rules of Criminal Procedure and Brady v. Maryland, 373 U.S. 83 (1963); and (2) denied Defendant’s motion for a new trial. The Supreme Court held (1) no Brady or Rule 16 argument regarding the investigative notes was preserved for appeal; and (2) the trial justice did not err by overlooking or misconceiving material evidence in denying Defendant’s motion for a new trial. View "State v. Blandino" on Justia Law

The Supreme Court vacated the judgments of conviction entered in the superior court following a jury trial convicting Defendant of three counts of assault with a dangerous weapon and one count of carrying a pistol without a license. The Supreme Court held (1) the superior court justice erred in denying Defendant’s motion to suppress evidence seized by police during a warrantless search of Defendant’s home because the state failed to overcome the presumption of unreasonableness that accompanies every warrantless entry into a home; and (2) the admission of the unlawfully seized evidence was not harmless beyond a reasonable doubt. View "State v. Terzian" on Justia Law

The Supreme Court affirmed Defendant’s convictions of-first degree murder and the discharge of a firearm while committing a crime of violence. On appeal, Defendant argued that the trial justice erred when “he refused to give an eyewitness identification jury instruction approved by this Court in State v. Werner, 851 A.2d 1093, 1002 (R.I. 2004).” The Supreme Court disagreed, holding that the trial court did not err and comported with case law when it denied Defendant’s request for a jury instruction on eyewitness identification, which instruction Defendant wished to be taken verbatim from Werner. View "State v. Fuentes" on Justia Law

The Supreme Court vacated Defendant’s convictions of three counts of first-degree murder, three counts of discharging a firearm while committing a crime of violence, and one count of conspiracy to commit robbery. Defendant was sixteen years old when he was identified as the shooter during an attempted robbery. Before trial, new information came to light, and the State’s theory of the case indicated that Defendant was not the shooter. On appeal, Defendant argued that the trial court erred by admitting R.I. R. Evid. 404(b) evidence. The Supreme Court agreed, holding that the evidence had slight probative value, if any at all, with respect with Defendant, and, moreover, was highly likely to have had an unduly prejudicial impact on the jury. Therefore, the admission of the evidence was not harmless beyond a reasonable doubt. View "State v. Husband" on Justia Law