Justia Rhode Island Supreme Court Opinion Summaries

In 2012, the Cranston Police Department filed delinquency petitions alleging that, when B.H. was 13 years old, he committed two offenses that, if committed by an adult, would constitute the offense of first-degree child molestation and one offense that, if committed by an adult, would constitute the offense of second-degree child molestation. The victims were 11-year-old boys.The Family Court found the B.H. delinquent for the violations under G.L. 1956 11-37-8.1 and 11-37-8.2. The Rhode Island Supreme Court remanded, finding that the evidence at the delinquency proceeding was insufficient to establish sexual penetration—an element of both of the charges of first-degree child molestation of which the respondent was adjudged to be delinquent. The court directed the Family Court to enter adjudications of delinquency on the lesser-included offense of second-degree child molestation sexual assault (second-degree child molestation). View "In the Matter of B.H." on Justia Law

Defendant was charged with one count of possession of cocaine. Defendant moved to suppress physical evidence seized and statements made to the police, arguing that he was arrested without probable cause and that the subsequent search of his jacket was unconstitutional. The trial justice denied the motion, determining that police had probable cause to arrest Defendant. After a trial, the jury convicted Defendant of the charged offense. The Supreme Court vacated the judgment of conviction, holding that Defendant’s arrest was not supported by probable cause, and therefore, his motion to suppress should have been granted. View "State v. Ray" on Justia Law

In 2010, the General Assembly amended R.I. Gen. Laws 12-19-18 to provide that a sentence of imprisonment after a finding of probation violation shall be quashed and the imprisonment terminated in certain circumstances occurring after a judgment of probation violation. In 2009, Defendant pled nolo contendere to felony assault. In 2012, while on probation, Defendant was charged with second-degree sexual assault and robbery. The State filed a notice of probation violation based on the conduct giving rise to these charges. The trial justice declared Defendant to be a probation violator and ordered him to serve two years of his suspended sentence. Thereafter, Defendant was acquitted on both counts. Defendant filed a motion to terminate his imprisonment. The trial justice denied Defendant’s motion, concluding (1) application of section 12-19-18(b) required impermissible retroactive application of the 2010 amendment; and (2) even if applied prospectively, section 12-19-18(b) constituted an unconstitutional exercise of judicial power by the General Assembly. The Supreme Court vacated the judgment of the superior court, holding (1) this case entails prospective, not retroactive, application of the statute; and (2) the trial justice was without authority to decide, sua sponte, a constitutional issue that was not raised by the parties. View "State v. Beaudoin" on Justia Law

In 2009, Defendant pled nolo contendere to one count of felony assault. Defendant was sentenced to a term of imprisonment and the balance suspended with probation. In 2012, the State filed a notice of probation violation alleging that Defendant failed to comply with the condition of his probation that he keep the peace and be of good behavior. After a violation hearing, the hearing justice found that Defendant had violated the conditions of his probation and ordered Defendant to serve two years of his suspended sentence. The Supreme Court affirmed, holding that the hearing justice acted neither arbitrarily nor capriciously in finding that Defendant violated the conditions of his probation on the basis of the evidence presented by the State. View "State v. Beaudoin" on Justia Law

Defendant was charged with eight counts of first-degree child molestation. Defendant filed a motion to suppress statements he made after his arrest and during his interrogations at the police department, claiming that the statements were coerced and not made voluntarily. The trial justice denied Defendant’s motion to suppress after a hearing. After a trial, the jury returned guilty verdicts on two of the eight counts of first-degree child molestation. Defendant appealed, arguing that the trial justice erred by denying his motion to suppress statements he made to the police during his post-arrest interrogation. The Supreme Court remanded to the superior court for additional fact-finding and credibility determinations. On remand and after a hearing, the trial justice denied Defendant’s motion to suppress his confession. The Supreme Court affirmed, holding that, under the totality of the circumstances, Defendant’s confession was voluntary and was not the product of coercion or impermissible conduct on the part of the interrogating detectives. View "State v. Bojang" on Justia Law

Defendant was charged with two counts of second-degree child molestation. After a jury trial, Defendant was convicted on Count 1 and acquitted on Count 2. Defendant appealed, arguing that the trial justice erred in his instructions to the jury and by employing the jury-verdict form. Specifically, Defendant asserted that the trial justice failed adequately to inform the jury of the distinction between Counts 1 and 2, which were identically worded. The Supreme Court affirmed the judgment of the superior court, holding that, while the issue was not properly preserved for review on appeal, it also lacked merit because there was no evidence in the record to indicate that the jury suffered from any confusion between Counts 1 and 2. View "State v. Hunt" on Justia Law

After a jury trial, Defendant was convicted of assault with a dangerous weapon. Defendant was sentenced to five years’ imprisonment, suspended, with five years of probation. The Supreme Court affirmed the judgment of conviction, holding (1) the trial justice did not err in barring testimony from one of the responding police officers, which concluded that Defendant was afraid of the complaining witness, on the grounds that the testimony was inadmissible hearsay; and (2) the trial justice did not overlook or misconceive material evidence or clearly err in denying Defendant’s motion for a new trial. View "State v. Williams" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and related crimes. Defendant appealed, arguing that the trial justice erred in (1) failing to grant his motion to suppress evidence that was obtained as a result of his warrantless arrest in his home, and (2) failing to remove two allegedly biased jurors from the jury or, in the alternative, to grant a mistrial. The Supreme Court vacated the judgment of the superior court and remanded for a new trial, holding (1) the trial justice erred in denying Defendant’s motion to suppress, as the warrantless entry into Defendant’s home was not consented to freely and voluntarily, and the State failed to establish the existence of exigent circumstances to justify the entry into the home; and (2) the error in this case was not harmless. Remanded for a new trial. View "State v. Gonzalez" on Justia Law

After a jury trial, Defendant was convicted of one count of breaking and entering. The trial justice sentenced Defendant to a term of incarceration and also adjudged Defendant to be a habitual offender. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not err in (1) denying Defendant’s motion for a judgment of acquittal, as there was sufficient evidence to support Defendant’s conviction; (2) limiting the scope of Defendant's cross-examination of the State’s fingerprint expert; and (3) denying Defendant's motion for a new trial, as the trial justice performed the requisite analysis and provided an adequate rationale for denying the motion. View "State v. Isom" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, failure to report a death with the intention of concealing a crime, obstruction of a firefighter while in the execution of his duty, and violation of a no-contact order. Defendant filed a motion for a new trial, which the trial justice denied. The Supreme Court upheld the trial justice’s denial of Defendant’s motion for a new trial, holding that, based on the Court’s review of the record and the trial justice’s application of the required three-step analysis, and after consideration of Defendant’s contentions, the trial justice was neither clearly wrong nor misconceived or overlooked material evidence when she denied Defendant’s motion for a new trial. View "State v. Greenslit" on Justia Law