Justia Rhode Island Supreme Court Opinion Summaries

In 1996, Defendant entered a plea of nolo contendere to several sex offenses and was sentenced to a term of incarceration. After Defendant was released on probation, he applied for a transfer of his probation supervision from Rhode Island to Pennsylvania pursuant to the Interstate Compact for Adult Offender Supervision (ICAOS). Pennsylvania accepted the transfer request and imposed additional conditions of supervision upon Defendant. Defendant violated the additional conditions. As a result, the State of Rhode Island filed a notice of probation violation. The probation violation hearing justice adjudged Defendant to be a probation violator, determining that ICAOS rules mandated that he treat the violations to which Defendant admitted as a violation of his Rhode Island probation. The hearing justice then executed eight years of Defendant’s suspended sentence and imposed new conditions of probation. The Supreme Court affirmed in part and vacated in part, holding (1) the hearing justice did not act arbitrarily and capriciously in finding that Defendant violated the terms and conditions of his probation; (2) the hearing justice did not abuse his discretion in ordering Defendant to serve eight years of his suspended sentence; but (3) in imposing two additional conditions, the hearing justice plainly exceeded his statutory jurisdiction. View "State v. Brown" on Justia Law

After a jury trial, Defendant was convicted of assault with a dangerous weapon and vandalism. Defendant appealed, arguing that the trial justice erred in granting the State’s motion to preclude Defendant from discussing self-defense in his closing argument and by refusing to instruct the jury on the law of self-defense. The Supreme Court vacated Defendant’s conviction for felony assault with a dangerous weapon, holding (1) the trial justice erred by refusing to include a self-defense instruction in the jury charge; and (2) the holding with respect to the felony assault conviction does not affect Defendant’s conviction for vandalism. View "State v. Soler" on Justia Law

In 1994, Applicant entered a plea of nolo contendere to the offense of maintaining a narcotics nuisance. In 2012, Applicant filed a pro se application seeking to vacate his nolo contendere plea. In his application Applicant argued that his plea was not knowing, intelligent, and voluntary and that his counsel provided ineffective assistance. The hearing justice entered judgment for the State and dismissed the application. The Supreme Court affirmed, holding (1) the trial justice did not err in finding that Applicant understood the nature and consequences of his plea; (2) the trial justice properly dismissed Applicant’s claims of ineffective assistance of counsel; and (3) the efforts of postconviction counsel were adequate. View "Reyes v. State" on Justia Law

The family court entered a decree that terminated Respondent’s parental rights. The decree rested primarily on Respondent's criminal convictions, including a conviction for first-degree murder. While Respondent’s appeal was pending, the Supreme Court vacated Respondent’s criminal convictions and corresponding sentences, and the case was remanded for a new trial. The Supreme Court vacated the decree terminating Respondent’s parental rights, holding that, without Respondent's criminal convictions and lengthy incarceration, the family court did not have sufficient factual support to find that Respondent was an unfit parent. Remanded for further proceedings. View "In re Izabella G." on Justia Law

After a jury trial, Defendant was convicted of possession of a controlled substance with intent to deliver, possession of a firearm while in possession of a controlled substance with intent to deliver, and conspiracy to possess a controlled substance with intent to deliver. The Supreme Court vacated the judgment of conviction, holding that the trial justice erred in refusing to allow Defendant to make an opening statement to the jury without affording him the opportunity to articulate the nature of the purportedly affirmative evidence he intended to elicit on cross-examination of the state’s witnesses. View "State v. Martinez" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and related crimes. Defendant was sentenced to life imprisonment on the murder count. Defendant appealed, arguing that the trial court erred by denying his motion to suppress the confession he made to the police, denying his motion for a new trial, and making certain evidentiary rulings at trial. The Supreme Court affirmed, holding (1) the court properly denied Defendant’s motion to suppress; (2) the challenged evidentiary rulings were correctly made; and (3) the trial justice did not overlook or misconceive material evidence in denying Defendant’s motion for a new trial. View "State v. Garcia" on Justia Law

In 2012, Applicant filed an amended application for postcoviction relief asserting that his convictions in four prior drug-offenses cases were the result of ineffective assistance of counsel because he had pled nolo contendere in each case rather than pursuing a motion to suppress evidence or going to trial. The hearing justice denied Applicant’s postconviction relief application, concluding that Applicant failed to prove that any of his attorneys’ performances were constitutionally deficient. The Supreme Court affirmed, holding that Applicant failed to demonstrate that any of his attorneys provided ineffective assistance of counsel in his previous cases. View "Lipscomb v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree arson. The trial justice sentenced Defendant to a term of twenty-five years’ imprisonment. The Supreme Court affirmed the judgment of conviction, holding (1) any error on the part of the trial court in admitting into evidence a video recording of Defendant’s custodial police interrogation, the error was not so prejudicial as to require a new trial; and (2) the trial court did not misconceive or overlook material evidence or otherwise err by denying Defendant’s motion for a new trial. View "State v. Gaudreau" on Justia Law

This case involved a shooting that occurred in the City of Woonsocket, which left Ikey Wilson with severe injury to his stomach and required the amputation of his right leg. Defendant Christian Rosado appealed his conviction on two separate counts of assault with a dangerous weapon (firearm). Defendant maintained that the hearing justice erred in denying his motion for a mistrial based on what he perceived to have been the state’s discovery violation. Finding no reversible error, the Supreme Court affirmed. View "Rhode Island v. Rosado" on Justia Law

Applicant Robert Dominick appealed the denial of his application for postconviction relief, arguing the trial court erred in finding that he failed to present newly discovered evidence that would have entitled him to a new trial. Applicant was convicted in 2009 for the assault and battery of a person over sixty years old. The victim testified that an altercation arose when she was mowing her lawn, and Applicant yelled at her to get off his lawn. Applicant shoved her against a granite marker pole located on her property, causing scrapes to her arm. The lawn mower was damaged as a result of the altercation. During the hearing and in his filings before the Superior Court, applicant relied on two items he described as "newly discovered": (1) the picture of the lawn mower, coupled with the information that Beltram had disposed of the lawn mower, and (2) an eyewitness' testimony. Applicant claimed that during the civil trial he learned for the first time that the victim had destroyed the lawn mower involved in their altercation but that she had kept a photograph of the lawn mower. He claimed that the photograph could have been used to impeach the victim's testimony at the criminal trial that the lawn mower had been damaged as a result of applicant’s conduct because the photograph did not depict any damage to the lawn. After considering the parties’ written and oral submissions and reviewing the record, the Rhode Island Supreme Court concluded the trial court did not err in finding Applicant failed to present new evidence, and affirmed in all respects. View "Dominick v. Rhode Island" on Justia Law