Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of possession of cocaine with intent to deliver. Defendant was sentenced to a term of fifteen years’ incarceration, with five years to serve and ten years suspended, with probation. The Supreme Court affirmed, holding (1) the trial justice did not err by denying Defendant’s motion for judgment of acquittal, as the State presented sufficient evidence from which a reasonable juror could find beyond a reasonable doubt that Defendant committed the offense; and (2) the issue of whether the trial justice erred by not instructing the jury on the lesser-included offense of simple possession was not properly before the Court for review. View "State v. Maria" on Justia Law

After a jury-waived trial, Defendant was convicted of domestic simple assault and domestic disorderly conduct. The Supreme Court affirmed the judgment, holding (1) sufficient competent and credible evidence existed in the record to support the trial justice’s finding beyond a reasonable doubt that Defendant committed the offenses; (2) the trial justice did not err in her credibility determinations and factual findings and applied the correct burden of proof with respect to Defendant’s claim of self-defense; (3) the trial justice did not abuse her discretion in her evidentiary rulings and or in limiting cross-examination; and (4) the trial justice did not overlook or misconceive material evidence in denying Defendant’s motion for a new trial. View "State v. Van Dongen" on Justia Law

After a jury trial, Appellant was convicted of conspiracy to commit assault with a dangerous weapon and assault with a dangerous weapon. Appellant was also charged with first-degree murder, but the jury was unable to reach a verdict on that charge. After a second jury trial, Appellant was convicted of one count of first-degree murder. Appellant later filed an application for postconviction relief, arguing that his second trial was not fair because the justice who presided over that trial had previously represented Appellant in family court when Appellant was a minor. Appellant also alleged that his counsel at the second murder trial was ineffective. After a hearing, the hearing justice denied postconviction relief. The Supreme Court affirmed, holding (1) the hearing justice did not err in denying postconviction relief on the grounds that the trial justice at Appellant’s second murder trial should have recused; and (2) Appellant’s counsel did not provide ineffective assistance at Appellant’s second murder trial. View "Perry v. State" on Justia Law

After a jury trial, Defendant was convicted of felony assault with a dangerous weapon, discharging a firearm while committing a crime of violence, and carrying a handgun without a license. Defendant appealed, arguing primarily that the trial justice erred in denying his motion for a new trial because the testimony of the victim was not credible. The Supreme Court affirmed, holding (1) the trial justice did not clearly err or overlook or misconceive relevant and material evidence in concluding that the victim was a credible witness; and (2) any alleged shortcomings in the investigation in the aftermath of the shooting were harmless. View "State v. Roldan" on Justia Law

After a jury trial, Defendant was found guilty of murder, using a firearm while committing a crime of violence resulting in a death, and carrying a pistol without a license. Defendant appealed, asserting a number of arguments. The Supreme Court affirmed the judgments of convictions, holding (1) the trial justice did not err when he declined to give a specific limiting instruction requested by Defendant to disregard a statement that the State gave during opening statements; (2) the trial justice did not abuse his discretion in denying Defendant’s request for “some sort of Neil v. Biggers identification instruction; (3) Defendant failed to preserve for appeal his argument that the trial justice admitted prejudicial evidence; and (4) the trial justice did not err when he denied Defendant’s motion for a new trial. View "State v. Davis" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, conspiracy to commit murder, and related crimes. Defendant appealed, arguing that the trial justice erred in (1) admitting prior testimony of a witness at a coconspirator’s trial about Defendant’s level of intoxication on the night of the shooting; and (2) denying Defendant’s motion for a new trial on the grounds that the verdict was against the weight of the evidence. The Supreme Court affirmed, holding (1) any prior testimony that was admitted, by any means, regarding Defendant’s level of intoxication was immaterial to his defense, and Defendant did not suffer prejudice; and (2) the trial justice properly assessed the weight of the evidence and the credibility of the witnesses and articulated adequate reasons for denying Defendant’s motion. View "State v. Offley" on Justia Law

After a jury trial, Defendant was found guilty of second degree murder. Defendant was sentenced to a term of forty years’ imprisonment. The Supreme Court affirmed, holding that the trial justice did not err in (1) instructing the jury concerning Defendant’s claim of accidental homicide; (2) allowing the State some flexibility to pose questions in yes-or-no form; (3) failing to declare a mistrial after the prosecutor discussed testimony with the State’s witness, a medical examiner, during breaks in the witness’s testimony; and (4) allowing admission of a seven-and-a-half minute video depicting the scene of the murder, including the victim’s body. View "State v. Fry" on Justia Law

After a jury trial, Defendant was convicted of assault with a dangerous weapon and other firearm-related offenses. Defendant appealed, arguing that the trial justice erred in denying his motion for a new trial because two key witnesses were not credible and the forensic evidence failed to conclusively link him to the shooting. The Supreme Court affirmed, holding that there was no basis for concluding that the trial justice committed clear error or that he overlooked or misconceived material evidence when he determined that the weight of the evidence supported the convictions and thus denied Defendant’s motion for a new trial. View "State v. Lopez" on Justia Law

After a jury-waived trial, Defendant was convicted of five counts of stalking. The trial justice imposed a sentence of probation on each count, to run concurrently. The Supreme Court affirmed, holding (1) the trial justice did not err when she denied Defendant’s motion to dismiss because he was “without knowledge that his actions were disturbing”; (2) the trial justice did not err when she denied Defendant’s motion to dismiss counts three through five because the State failed to call three of the five complainants to testify; and (3) Defendant’s remaining arguments on appeal were not properly before the Supreme Court. View "State v. Kolsoi" on Justia Law

After a jury trial, Defendant was convicted of first-degree child molestation. The Supreme Court vacated the conviction and remanded for a new trial, determining that Defendant’s right to counsel was violated by the admission at trial of a statement he made to an agent of the state. After a second trial, the jury found Defendant guilty of first-degree child molestation. The trial justice sentenced Defendant to life imprisonment. The Supreme Court affirmed, holding (1) the forty-five-month delay between the return of the record to the superior court after Oliveira I and the commencement of Defendant’s retrial did not violate Defendant’s right to a speedy trial; and (2) the trial justice did not abuse his discretion in admitting certain out-of-court statements into evidence. View "State v. Oliveira" on Justia Law