Justia Rhode Island Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court affirmed the judgment of the superior court denying Defendant's motion for entry of a judgment of acquittal and convicting him on thirteen counts stemming from his alleged misuse of his position as detective commander in the Middletown Police Department, holding that Defendant's argument on appeal was waived.Defendant was convicted of several counts for assisting an individual to attain a house choice voucher from the Newport Housing Authority. Defendant appealed the denial of his motion for judgment of acquittal on the basis of his contention that "[a]ny rules governing the user's behavior within the system are irrelevant and cannot contribute to the sufficiency of the state's case in a [Sup. Ct. R. Crim. P. 29] motion...." The Supreme Court affirmed, holding that Defendant's argument was waived because it was not the same argument he made below. View "State v. Gamache" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court convicting and committing Defendant on one count of first-degree sexual assault after a jury trial, holding that there was no prejudicial error in the proceedings below.Defendant was convicted after a jury trial and sentenced to thirty-eight years at the Adult Correctional Institutions. On appeal, Defendant challenged the ruling of the trial justice permitting the State to introduce into evidence testimony given by a nurse concerning what the complaining witness told her about the alleged sexual assault. The Supreme Court affirmed, holding (1) Defendant's arguments on appeal were properly before the Court; (2) the was no error in the discretionary decision of the trial justice to admit the nurse's testimony; and (3) certain portions of admitted statements were erroneously admitted, but the evidence was clearly harmless cumulative evidence. View "State v. White" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the decision of the superior court dismissing Plaintiffs' claims in favor of Defendants in accordance with Sup. Ct. R. Civ. P. 12(b)(6), holding that the trial court did not err in ruling that R.I. Gen. Laws 9-1-51 (the act), as amended, created a class of criminal actors beyond the scope of actual perpetrators as set forth in the act.Plaintiffs filed separate actions alleging that they were sexually molested as minors by priests at the Roman Catholic Diocese of Providence. Plaintiffs claimed that Defendants' actions rose to the level of criminal aiding and abetting, thus constituting improper conduct. The trial justice granted Defendants' motions to dismiss all claims in all cases, holding that because Defendants were non-perpetrators, the actions were time-barred. The Supreme Court affirmed, holding (1) Defendants could not be found culpable as aiders or abettors; (2) even if Defendants' actions constituted a violation of a criminal statute, they were non-penetrators and the claims were time-barred; and (3) there was no other error. View "Houllahan v. Gelineau" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court convicting Defendant of two counts of second-degree sexual assault, holding that the trial justice did not err in denying Defendant's motion to pass the case or his motion for a new trial.Defendant was convicted after a trial. The trial justice denied Defendant's motion for a new trial and sentenced him to eight years of imprisonment for each count, with one year to serve and the remaining time suspended. On appeal, Defendant argued, among other things, that the trial justice abused his discretion in denying Defendant's motion to pass the case due to the prosecutor's allegedly improper comments during closing arguments. The Supreme Judicial Court affirmed, holding (1) the trial justice did not abuse his discretion in denying Defendant's motion to pass the case; and (2) the trial justice did not erroneously admit evidence unduly prejudicial to Defendant, and therefore, Defendant was not entitled to receive a new trial. View "State v. Leonard" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgments of the superior court convicting Defendant following a jury trial for larceny of an automobile and adjudicating him a probation violator, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued, among other things, that the trial court erred in denying his motion to suppress certain evidence collected as a result of a warrantless search of his real-time cell-site location information (CSLI). The Supreme Court disagreed and affirmed, holding (1) the acquisition of real-time CSLI qualifies as a search under the Fourth Amendment for which a warrant is required; (2) any error in the trial justice's determination that the exigent circumstances exception to the warrant requirement applied to the facts of this case was harmless; (3) the trial justice did not abuse his discretion in denying Defendant's motion to exclude certain testimony, and any error in allowing other testimony to be admitted at trial was harmless; and (4) Defendant waived his last argument for appeal. View "State v. Sinapi" on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of five counts of first-degree robbery and three counts of conspiracy to commit robbery, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued that the trial court erred in failing to exclude statements he made during a post-arrest police interview and in denying his motion for a new trial. The Supreme Court disagreed and affirmed, holding (1) the trial justice did not abuse his discretion by admitting Defendant's statements about firearms as probative of his opportunity, intent, preparation, or plan to supply a weapon for the robberies and conspire to commit the robberies; and (2) the prejudice arising from Defendant's "highly relevant" statements substantially outweighed their probative value. View "State v. Reverdes" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the superior court denying Defendant's motion to correct an illegal sentence, holding that there was no error on the part of the trial justice in denying Defendant's motion to correct his sentence.After a jury trial, Defendant was convicted of two counts of assault with a dangerous weapon in a dwelling house. As part of his sentence and as relevant to this appeal, Defendant received a ten-year nonparolable sentence enhancement as a habitual offender to be served consecutively to his first sentence. Defendant later filed a motion to correct an illegal sentence, arguing that his habitual offender sentence enhancement was illegal. The trial justice denied the motion. The Court of Appeals affirmed, holding that the trial justice correctly complied with the habitual offender statute. View "State v. Davis" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court declaring Defendant to be in violation of the terms and conditions of his probation, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that there was a lack of sufficient evidence to support a finding that he had violated his probation and, alternatively, that the trial justice imposed an excessive sentence for the violation. The Supreme Court affirmed, holding that the trial justice (1) did not act arbitrarily or capriciously in concluding that Defendant had violated his probation; and (2) did not abuse his discretion sentencing Defendant to thirty-six months of his suspended sentences, two months to remain suspended. View "State v. Perkins" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court convicting Defendant of felony assault resulting in serious bodily injury and sentencing him to a term of twenty years at the Adult Correctional Institutions, holding that any error was harmless.On appeal, Defendant argued that the trial justice erred in admitting evidence that he struck an unrelated person in an unrelated event earlier on the evening in question, in violation of R.I. R. Evid. 404(b) and 403. The Supreme Court affirmed the conviction, holding (1) the admission of the challenged evidence was an abuse of discretion; but (2) the error did not contribute to the jury's evaluation of the evidence and Defendant's conviction and amounted to harmless error. View "State v. DeCosta" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court in granting summary judgment in favor of Defendants, Rhode Island College and related individuals, on the grounds of qualified immunity, holding that Plaintiff was not entitled to relief on his claims of error.Plaintiff brought this action seeking equitable relief and damages under 42 U.S.C. 1983 and 1988 on the grounds that Defendants' conduct toward him during his Master of Social Work program violated his First and Fourteenth Rights. The superior court concluded that Defendants were entitled to qualified immunity and granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding that Plaintiff's arguments on appeal were unavailing. View "Felkner v. R.I. College" on Justia Law