Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s convictions for one count of first-degree robbery, two counts of felony assault, one count of second-degree murder, and one count of committing a crime of violence while possessing a firearm. On appeal, Defendant challenged the evidentiary rulings of the trial justice and the trial justice’s denial of his motion for a new trial. The Supreme Court affirmed, holding (1) there was no prejudicial error in the trial justice’s evidentiary rulings; and (2) the trial justice did not overlook or misconceive material evidence, nor was he otherwise clearly wrong, in denying Defendant’s motion for a new trial. View "State v. Adams" on Justia Law

The doctrine of collateral estoppel did not bar the state from prosecuting a chemical breath test refusal under R.I. Gen. Laws 31-37-2.1.Defendant was convicted of unlawful possession of marijuana and a chemical refusal. The Supreme Court remanded the case to the superior court for an evidentiary hearing on the issue of whether Defendant’s motion to dismiss on grounds of collateral estoppel was timely. The superior court found that Defendant’s motion was untimely filed but that there was good cause for the delay. Before the Supreme Court, Defendant argued that the state was collaterally estopped from prosecuting the chemical refusal because the facts at issue were decided in the Traffic Tribunal. The Supreme Court affirmed the judgment of conviction, holding that collateral estoppel did not apply under the circumstances of this case. View "State v. Pacheco" on Justia Law

Defendant was convicted of constructive possession of a firearm after a conviction for a crime of violence. Defendant appealed. The Supreme Court affirmed, holding (1) the trial justice did not err in refusing to suppress Defendant’s post-arrest statement to the police with respect to the gun at issue in this case; (2) Defendant waived the issue of whether the trial judge erred in declining to submit to the jury the issue of the voluntariness of Defendant’s alleged statement with respect to the gun at issue; and (3) the trial justice did not err in denying Defendant’s motion for judgment of acquittal and motion for a new trial. View "State v. Yon" on Justia Law

The trial court did not err in declining to suppress the statements Defendant had given tot he police.Defendant was convicted on two counts of first-degree sexual assault. The trial court sentenced Defendant to twenty-five years on both counts, to run concurrently. Defendant appealed the denial of his motion to suppress the statements that he had given to the police, arguing that the State failed to meet its burden of demonstrating, by clear and convincing evidence, that he knowingly, intelligently, and voluntarily waived his constitutional rights under Miranda v. Arizona, 384 U.S. 436 (1966). The Supreme Court affirmed, holding (1) the hearing justice’s finding that Defendant’s statements were not invited by the police but were voluntary statements was correct; (2) Defendant’s post-Miranda statements were admissible because the detectives did not engage in the “question first” interrogation technique found unconstitutional in Missouri v. Seibert, 542 U.S. 600 (2004); and (3) there was no evidence that Defendant failed to comprehend the nature of his rights or the consequences of abandoning them when he made statements while in custody at the police station. View "State v. Sabourin" on Justia Law

Defendant was charged via a criminal information with breaking and entering a dwelling. After a trial, the trial justice granted Defendant’s motion to pass the case based on based on a comment made by the prosecutor during closing argument. Thereafter, Defendant filed a motion to dismiss the information on grounds of double jeopardy. The trial justice denied Defendant’s motion to dismiss, ruling that the State’s actions were not intended to goad Defendant into seeking a mistrial. The Supreme Court affirmed, holding that the trial justice did not err in determining that the prosecutor did not intentionally goad Defendant into moving for a mistrial. View "State v. Corleto" on Justia Law

Defendant pleaded nolo contendere to assault in a dwelling house with intent to murder while armed with a dangerous weapon and carrying a pistol on or about his person without a license. While Defendant was on parole, he was arrested and charged with domestic assault and failure to relinquish a telephone. Also while on parole Defendant was charged with breaking and entering. After a hearing, Defendant admitted that he violated the terms and conditions of his probation. Defendant later filed an application for postconviction relief alleging that he was denied the effective assistance of counsel at the probation violation hearing and that he did not knowingly, intelligently, and voluntarily admit a violation of probation. A hearing justice denied Defendant’s application for postconviction relief. The Supreme Court affirmed, holding (1) any alleged deficient performance by Defendant’s attorney was not so prejudicial as to deprive Defendant to a fair trial; and (2) Defendant’s admission was made knowingly, intelligently, and voluntarily. View "Gomes v. State" on Justia Law

After a jury trial, Defendant was convicted of six counts of first-degree sexual assault and three counts of second-degree sexual assault. The Supreme Court vacated count five of the judgment of conviction and affirmed the judgment of the superior court in all other respects, holding (1) the trial court did not err in declining to preclude certain testimony at trial under R.I. R. Evid. 404(b); and (2) although Defendant waived his appellate argument in this regard, the trial justice erred in denying Defendant’s motion for judgment of acquittal on count five of the indictment, and therefore, in the interest of justice and judicial economy, the judgment of conviction on count five is vacated. View "State v. Perez" on Justia Law

Defendant was convicted of second-degree robbery and sentenced to twenty years with sixteen years to serve at the Adult Correctional Institutions and four years suspended with probation. Defendant filed a motion for a new trial. The trial justice denied the motion, finding that “there was more than sufficient evidence” to support the conviction. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not overlook or misconceive material evidence in denying Defendant’s motion for a new trial, nor did he commit clear error in denying Defendant’s motion for a new trial. View "State v. Pittman" on Justia Law

The Supreme Court affirmed Defendant’s conviction for one count of domestic assault by strangulation and one count of simple assault. The court held that (1) the trial justice did not err in denying Defendant’s motion to pass the case after the prosecutor posed an allegedly prejudicial question to Defendant because the prosecutor’s question was not so inflammatory that the trial justice was unable to expiate the harm; and (2) the trial justice properly denied Defendant’s motion for judgment of acquittal on the grounds that Defendant was twice placed in jeopardy for the same act because Defendant was convicted of only one of the two counts at issue. View "State v. Funches" on Justia Law

Appellant was found guilty of two counts of felony assault with a dangerous weapon, conspiracy to commit assault with a dangerous weapon, and other offenses. Appellant filed a pro se application for postconviction relief, arguing that he received ineffective assistance of trial counsel. The trial justice denied postconviction relief. On appeal, Appellant argued that deficiencies on the part of trial counsel prejudiced him in his trial and conviction. The Supreme Court affirmed, holding that Appellant failed to meet his burden of establishing ineffective assistance of counsel entitling him to postconviction relief. View "Chum v. State" on Justia Law