Justia Rhode Island Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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After a jury trial, Defendant was found guilty of possession of more than five kilograms of marijuana. Defendant was sentenced to twenty years’ imprisonment. The Supreme Court affirmed, holding (1) Defendant waived her argument that the trial justice did not err in his supplemental jury instruction given in response to a question posed by the jury; (2) the trial justice did not err in denying Defendant’s motion for a new trial based on both the weight of the evidence and the sufficiency of the evidence; and (3) Defendant’s argument that her twenty-year sentence violated R.I. Const. art. I, 8 was not properly before the Court. View "State v. Mendez" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was found guilty of second-degree sexual assault. The trial justice denied Defendant’s motion for a new trial. The Supreme Court affirmed, holding that the trial justice (1) did not err in denying Defendant’s motion for judgment of acquittal, as sufficient evidence supported the conviction; (2) did not overlook or misconceive material evidence in denying Defendant’s motion for a new trial; and (3) did not err in allowing the complaining witness’s statements made to the police officer at the scene into evidence at trial under the excited-utterance exception to the hearsay rule. View "State v. Gomez" on Justia Law

Posted in: Criminal Law
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In 2006, Defendant was found guilty of breaking and entering, assault with a dangerous weapon, and simple assault. In 2012, while he was incarcerated, Defendant was involved in an altercation with a correctional officer. As a result, the state initiated probation-violation proceedings seeking to revoke the suspended portion of Defendant’s sentence for felony assault. The hearing justice ultimately found that Defendant was the aggressor in this case and that he had violated in the terms of his probation. The judge then ordered Defendant to serve the entirety of his thirteen-year suspended sentence. The Supreme Court affirmed the adjudication of probation violation, holding that the hearing justice acted neither arbitrarily nor capriciously by finding a violation on the basis of the evidence presented by the state. View "State v. Prout" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was found guilty of four criminal counts related to a murder committed during the course of an attempted robbery. The Supreme Court affirmed the superior court’s judgment of conviction and its denial of Defendant’s motion for a new trial, holding (1) in denying Defendant’s motion for a new trial, the trial justice did not improperly credit the testimony of three key witnesses; and (2) the trial justice did not err in allowing one witness to testify as to Defendant’s behavior during their romantic relationship because the testimony was relevant and only marginally prejudicial. View "State v. Virola" on Justia Law

Posted in: Criminal Law
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After a bench trial in district court, Defendant was convicted of one count of simple domestic assault and one count of resisting arrest. Defendant appealed these convictions to the superior court. Immediately before the start of trial, Defendant entered a plea of nolo contendere to the complaint of resisting arrest. After a jury trial, Defendant was found guilty of simple domestic assault. The trial court denied Defendant’s motion for a new trial and sentenced him to one year’s probation. The Supreme Court affirmed, holding that the trial justice did not err when he allowed into evidence the facts regarding the charge of resisting arrest. View "State v. Peltier" on Justia Law

Posted in: Criminal Law
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Defendant was charged by information with stealing over $500 in violation of R.I. Gen. Laws 11-41-1 and 11-41-5 and soliciting another to receive stolen goods in violation of R.I. Gen. Laws 11-1-9. The amount of money in question was $714. Subsequently, the Governor signed into law an act amending section 11-41-5 to increase the threshold for felony larceny from $500 to $1500. During trial, Defendant sought to have the larceny count amended and the solicitation charge amended due to the legislative change. The trial court proceeded with the counts as charged and convicted Defendant of having committed larceny over $500 and having solicited another to receive stolen goods over $500. The Supreme Court affirmed, holding that the trial justice was correct in determining that the general savings clause, R.I. Gen. Laws 43-3-23, was applicable and that the changes to section 11-41-5 should not be applied retroactively. View "State v. Whiting" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was found guilty of one count of second-degree sexual assault. The Supreme Court affirmed, holding that the trial justice did not err in (1) denying Defendant’s motion to suppress the complainant’s out-of-court identification because there was not likelihood of misidentification and because the photo array was not unnecessarily suggestive; (2) denying Defendant’s motion for a new trial, as the trial justice followed the proper procedure for assessing a challenge to the weight of the evidence, and there was no indication that he overlooked or misconceived material evidence; and (3) denying Defendant’s request for a specific set of jury instructions. View "State v. Austin" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was convicted of first-degree sexual assault and second-degree sexual assault and two counts each of assault with intent to commit second-degree sexual assault and of indecent solicitation of a minor. The Supreme Court affirmed the convictions, holding that the trial justice did not err in (1) denying Defendant’s motion for a bill of particulars, as the State provided Defendant with adequate notice of the charges; and (2) denying Defendant’s motion for a new trial, as the justice did not overlook or misconceive material evidence relating to a critical issue in this case. Remanded with directions to correct the final judgment to reflect the amended counts in the indictment. View "State v. Gregson" on Justia Law

Posted in: Criminal Law
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Defendant pled nolo contendere to uttering or delivering checks in an amount exceeding $1500 with intent to defraud, misappropriating property, and obtaining goods valued at more than $500 by false pretenses with intent to cheat or defraud. Defendant was ordered to pay $95,000 in restitution, in monthly installments of $500. Defendant later moved to reduce her monthly installments, claiming that she was only able to pay $237 per month and that, therefore, her payments should be reduced. The superior court denied Defendant’s request, concluding that Defendant had failed to establish that she was financially unable to make the restitution payments. The Supreme Court affirmed, holding that Defendant failed to meet her burden of proving an inability to maintain payments of $500 per month. View "State v. Rosenbaum" on Justia Law

Posted in: Criminal Law
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Defendant was charged with eleven offenses in a single indictment, most notably murder. After a jury trial, guilty verdicts were returned on all counts. The trial court sentenced Defendant to three consecutive life sentences plus an additional thirty-five consecutive nonparoleable years. The Supreme Court affirmed the judgments of conviction, holding (1) the trial justice did not abuse his discretion when he admitted character evidence under R.I. R. Evid. 404(b); and (2) the prosecutor did not make inappropriate or inflammatory comments during closing arguments that warranted a new trial. View "State v. Tucker" on Justia Law

Posted in: Criminal Law