Justia Rhode Island Supreme Court Opinion Summaries
Articles Posted in Criminal Law
State v. Matthews
After a jury trial, Defendant was found guilty of disorderly conduct and sentenced to six months’ incarceration. The Supreme Court affirmed the judgment of conviction and the denial of Defendant’s motion for a new trial and motion for a judgment of acquittal, holding (1) the trial justice did not err in denying Defendant’s motion for a new trial, as his speech rose to the level of the criminal offense with which he was charged; (2) there was sufficient evidence to convict Defendant; and (3) Defendant’s argument that the criminal complaint lodged against him was insufficient as a matter of law to place him on notice of the charge against him was not properly preserved for appellate review. View "State v. Matthews" on Justia Law
Lopes v. State
Defendant entered a plea of nolo contendere to the charges of burglary, breaking and entering, and receiving stolen goods. Defendant filed an application for postconviction relief, alleging several grounds for relief regarding the voluntariness of his plea and the performance of his trial counsel. After a hearing, the superior court denied Defendant’s application for postconviction relief, finding that Defendant failed to carry his burden of proof and establish his claim and that Defendant’s testimony was self-serving and not credible. The Supreme Court affirmed, holding that the trial justice did not err in its judgment. View "Lopes v. State" on Justia Law
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Criminal Law
Miller v. Metro. Prop. & Cas. Ins. Co.
Plaintiffs, David Miller and Miller’s Auto Body, alleged that they were subject to a malicious investigation into suspected insurance fraud that Defendants, three insurance companies, believed was taking place at Plaintiffs’ auto-body shop. Miller was charged with, among other charges, four counts of insurance fraud. The criminal information was dismissed by the Attorney General, but the dismissal was conditioned on an agreement between Miller and the Attorney General requiring Miller to execute a general liability release in favor of Defendants. More than one year after executing the release, Plaintiffs filed a complaint against Defendants. The trial court granted pretrial summary judgment for Defendants on the majority of Plaintiffs’ claims. Only Plaintiffs’ abuse-of-process claim went to trial. The jury returned verdicts in favor of Plaintiff against the two remaining defendants. The trial court subsequently granted judgment as a matter of law in favor of one defendant but denied the other defendant’s motion for judgment as a matter of law. The Supreme Court affirmed in part and reversed in part, holding that the release executed by Miller before he initiated suit barred all his claims against the defendants. View "Miller v. Metro. Prop. & Cas. Ins. Co." on Justia Law
State v. Armour
After a jury trial, Defendant was convicted of one count of second-degree child molestation. The Supreme Court affirmed the judgment, holding that the trial justice did not err in (1) denying Defendant’s motion to suppress an incriminating confession he gave to the police while in custody because the statement was given voluntarily; (2) permitting an attending physician at a child protection program who had examined the victim on the night of the incident to testify regarding the explanation of a normal examination over defense counsel’s objection; and (3) denying Defendant’s motion for judgment of acquittal, as there was sufficient evidence to support the conviction. View "State v. Armour" on Justia Law
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Criminal Law
State v. Rodriguez
After a jury trial, Defendant was found guilty of one count of delivery of a controlled substance (cocaine) and was sentenced to five years’ incarceration. The Supreme Court affirmed, holding that the trial justice did not err in (1) denying Defendant’s motion in limine to bar the testimony of two detectives; (2) instructing the jury; (3) failing to include certain portions of testimony during a read back to the jury; (4) denying Defendant’s motion for judgment of acquittal; and (5) denying Defendant’s motion for a new trial. View "State v. Rodriguez" on Justia Law
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Criminal Law
State v. Tully
After a jury trial, Defendant was convicted of first-degree felony murder and conspiracy to commit robbery. The Supreme Court affirmed, holding (1) the trial justice did not abuse his discretion in denying Defendant’s motion to pass the case due to an alleged discovery violation pursuant to Sup. Ct. R. Crim. P. 16 because, although Defendant framed the issue as one of insufficient disclosure, Rule 16 was, in fact, not implicated; and (2) the trial justice articulated adequate grounds for denying Defendant’s motion for a new trial and neither overlooked not misconceived material evidence, nor was otherwise clearly wrong, in making his decision. View "State v. Tully" on Justia Law
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Criminal Law
State v. Cruz
After a jury trial, Defendant was convicted of resisting arrest and disorderly conduct. Defendant appealed, asserting that her right to counsel guaranteed by both the federal and state Constitutions was violated when the trial justice allowed her to represent herself at trial without first determining whether she had made a knowing and intelligent waiver of her right to counsel. The Supreme Court affirmed, holding that, upon consideration of the totality of the circumstances at the time of Defendant’s waiver, the record established Defendant’s voluntary, knowing, and intelligent waiver of her right to counsel. View "State v. Cruz" on Justia Law
State v. Arciliares
After a jury trial, Defendant was convicted of murder in the first degree and other offenses. Defendant appealed, asserting, among other claims of error, that the trial justice erred by deciding to limit the extent to which Defendant was allowed to cross-examine a key police witness, the lead detective in the case. The Supreme Court agreed with Defendant and vacated his convictions, holding (1) the proffered evidence was relevant; (2) the witness’s testimony would not implicate the holding in State v. Harnois; and (3) R.I. R. Evid. 403 would not bar the witness’s testimony. Remanded for a new trial. View "State v. Arciliares" on Justia Law
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Criminal Law
State v. Storey
After a jury trial, Defendant was convicted of one count of assault with a dangerous weapon and one count of simple assault and battery. Defendant was sentenced to fifteen years imprisonment, with five years to serve and ten years suspended. The Supreme Court affirmed, holding (1) the trial justice did not err by denying Defendant’s motions for judgment of acquittal and new trial, as the evidence was sufficient to support the verdict; (2) the trial justice did not err by not allowing Defendant to cross-examine the complaining witness concerning custody issues involving her sons; and (3) Defendant’s challenge to his sentence was not properly before the Court for review. View "State v. Storey" on Justia Law
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Criminal Law
State v. Verry
After a second jury trial, Defendant was convicted of one count of felony assault, one count of simple assault, and one count of first-degree child abuse. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice (1) did not abuse his discretion by denying Defendant’s motion for a continuance in order for the defense to investigate genetic-testing results that were provided to the defense during jury selection in the second trial; and (2) did not err or violate Defendant’s right to present a defense by prohibiting Defendant’s father from testifying in Defendant’s case-in-chief. View "State v. Verry" on Justia Law