Justia Rhode Island Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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After a jury trial, Defendant was convicted of one count of felony domestic assault, two counts of assault with a dangerous weapon, and one count of simple domestic assault after previously having been convicted twice of domestic assault. The Supreme Court affirmed. Defendant later filed an application for postconviction relief, alleging that his trial counsel was ineffective because he stipulated to the fact that Defendant had two prior convictions for domestic violence in the presence of the jury. The Supreme Court affirmed, holding that trial counsel’s performance was not deficient, and even if Defendant were able to establish that his trial counsel was ineffective, Defendant’s right to a fair trial was not prejudiced by his trial counsel’s conduct. View "Snell v. State" on Justia Law

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Plaintiff was injured when he fell down the stairs in his residence. Plaintiff filed a negligence action against Defendants, his landlords, alleging that Defendants failed to maintain the premises in a clean and safe condition. After a trial, the jury returned a verdict for Defendants. The superior court entered judgment in accordance with the verdict. Plaintiff appealed, arguing that the trial justice erred by denying his motion to pass the case due to jury prejudice. The Supreme Court affirmed, holding that the trial justice did not commit reversible error by rejecting Plaintiff’s motion to pass the case due to juror misconduct. View "Roma v. Moreira" on Justia Law

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After a jury trial, Defendant was found guilty of three counts of first degree sexual assault and one count of assault with the intent to commit a sexual assault. Defendant appealed, arguing that the trial justice erred in permitting the State to impeach him with a prior conviction for assault and denying his motion for a new trial. The Supreme Court affirmed, holding (1) the trial justice did not abuse his discretion in concluding that Defendant’s assault conviction was admissible to impeach Defendant’s credibility; and (2) the trial justice was neither clearly wrong nor misconceived or overlooked material evidence in denying Defendant’s motion for a new trial. View "State v. Swiridowsky" on Justia Law

Posted in: Criminal Law