Justia Rhode Island Supreme Court Opinion Summaries

Defendant pled nolo contendere to one count of felony assault and received a deferred sentence. Thereafter, Defendant was presented with a notice of violation based on an alleged act of second-degree child molestation of Jessica, Defendant’s niece. After a trial, the jury acquitted Defendant of second-degree child molestation. The hearing justice, however, imposed on Defendant a twenty-five-year sentence with five years to serve, concluding that, by his sexual contact with Jessica, Defendant had violated the conditions of his deferred sentence. The Supreme Court affirmed, holding that the hearing justice did not act unreasonably or arbitrarily in finding that a violation of the conditions of Defendant’s deferred sentence had occurred. View "State v. Giard" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first-degree child molestation and two counts of second-degree child molestation. Defendant appealed, arguing that the trial justice erred in denying his motion for a new trial due to the purported lack of credibility on the part of the complaining witness and his half-brother and inconsistencies in their testimonies concerning the alleged molestations. The Supreme Court affirmed the superior court’s judgment of conviction, holding that the trial justice neither clearly erred nor overlooked or misconceived relevant evidence and that the trial justice properly denied Defendant’s motion for a new trial. View "State v. Muralles" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, conspiracy to commit murder, and using a firearm when committing a crime of violence. The Supreme Court affirmed, holding that the trial justice did not err in (1) denying Defendant’s motion for a new trial on the grounds of inconsistencies in the witnesses’ testimonies; (2) refusing to give an “empty chair” jury instruction due to a witness’s absence of trial; and (3) making certain evidentiary rulings challenged by Defendant. Further, Defendant’s argument that the cumulative effect of the alleged errors warranted reversal was without merit. View "State v. Moore" on Justia Law

Defendant was convicted of several criminal counts, including burglary and conspiracy to commit burglary. The aggregate sentences for all of Defendant’s convictions totaled thirty-five years. Defendant subsequently moved to reduce his sentence pursuant to Rule 35 of the Superior Court Rules of Criminal Procedure, arguing, inter alia, that he accepted responsibility for his actions and that his sentence violated the Eighth Amendment. The hearing justice denied Defendant’s motion to reduce sentence. On appeal, Defendant argued that his violated the Sixth Amendment and the Eighth Amendment. The Supreme Court affirmed, holding (1) the hearing justice was within his discretion to confirm Defendant’s punishment; (2) Defendant’s constitutional challenges were not cognizable in the context of a motion to correct an illegal sentence under Rule 35; and (3) even if Defendant could raise constitutional challenges under Rule 35, his arguments lacked merit. View "State v. Ciresi" on Justia Law

In 2009, Appellant entered a plea of nolo contendere to the offense of possession of between one to five kilograms of a controlled substance classified as marijuana, with knowledge and intent. In 2013, Appellant filed an application for postconviction relief seeking to vacate his 2009 nolo contendere plea, arguing that he neither knew nor understood the charges against him because a Haitian-Creole interpreter was not provided at his plea colloquy and that his trial counsel provided ineffective assistance. The hearing justice denied the postconviction-relief application. The Supreme Court affirmed, holding that the hearing justice did not err in finding that Appellant understood the plea colloquy. View "Duvere v. State" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree, discharging a firearm during a crime of violence, and conspiracy to commit murder. Defendant filed a motion for a new trial, arguing that the weight of the evidence did not support the verdicts in this case. The trial justice denied the motion. Thereafter, Defendant was sentenced to two mandatory consecutive sentences of life imprisonment for the murder and firearm convictions. The Supreme Judicial Court affirmed the judgments of convictions, holding that the trial justice did not overlook or misconceive material evidence or clearly err when he credited the testimony of Defendant’s co-conspirators. View "State v. Lopez" on Justia Law

After a jury trial, Defendant was found guilty of one count of assault with a dangerous weapon in a dwelling house and one count of breaking and entering of a dwelling house. The Supreme Court affirmed, holding (1) with respect to the breaking and entering count, the trial justice did not err in denying Defendant’s motion for a judgment of acquittal and his motion for a new trial because the State proved beyond a reasonable doubt that Defendant lacked consent to enter the house; and (2) the trial justice did not err in denying Defendant’s motion for a new trial on the assault with a dangerous weapon in a dwelling house count because the verdict was not against the weight of the evidence and the trial justice did not overlook or misconceive material evidence. View "State v. Grantley" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder, possessing a firearm after having previously been convicted of a violent crime, and other crimes. Defendant was sentenced to consecutive life sentences for first-degree murder and using a firearm during a violent crime. Defendant appealed, arguing that the trial justice erred in excluding the testimony of Stephen Bodden on the grounds that Bodden effectively invoked his Fifth Amendment privilege against self-incrimination. The Supreme Court affirmed, holding (1) Defendant’s appeal was not properly before the Court; and (2) nonetheless, the trial justice did not err when he ruled that Bodden properly invoked his Fifth Amendment privilege during the voir dire examination. View "State v. Barros" on Justia Law

After a jury-waived trial, Defendant was convicted of felony assault on a police officer, simple assault on a police officer, resisting arrest, driving under the influence of alcohol, and obstructing a police officer. During trial, the testimony each side presented diverged significantly, and the trial justice’s guilt assessment turned on his impression of witness credibility. The Supreme Court affirmed, holding that sufficient credible and competent evidence supported the trial justice’s guilt determinations on all counts beyond a reasonable doubt, and the trial justice did not overlook or misconceive any material evidence in reaching his decision. View "State v. Edwards" on Justia Law

In 1992, a jury found Defendant guilty of murder in the first degree. The Supreme Court affirmed the conviction. In 2004, Defendant filed an application for postconviction relief pursuant to Rhode Island’s Innocence Protection Act. For almost a decade, various orders were entered and discovery took place. In 2015, Defendant filed a second amended application for postconviction relief. The hearing justice granted Defendant’s application for postconviction relief and vacated his conviction, finding two Brady violations based on the State’s suppression of favorable evidence and a due process violation resulting from the police department’s unduly suggestive interviewing of witnesses. The Supreme Court affirmed the superior court’s judgment vacating Defendant’s conviction, holding that the hearing justice erred in vacating Defendant’s conviction on the basis of the former prosecutor’s failure to disclose pretrial statements of one of the State’s witnesses, and this claim of error was dispositive of the State’s appeal. View "Tempest v. State" on Justia Law