Justia Rhode Island Supreme Court Opinion Summaries

Defendant was adjudicated by a justice of the superior court to be in violation of the terms and conditions of his probation for his participation in a home invasion. Defendant appealed, arguing that the trial justice acted arbitrarily and capriciously in finding him to be a probation violator. The Supreme Court entered an order directing the parties to appear and show cause why the issues raised in this appeal should not be summarily decided. The Court then determined that cause had not been shown and affirmed, holding that the trial justice did not act arbitrarily or capriciously in finding that Defendant violated the terms of his probation. View "State v. Gibson" on Justia Law

A criminal complaint was filed against Defendant charging him with burglary. After a combined bail and violation hearing, a hearing justice found that Defendant failed to be of good behavior and that Defendant violated the terms of his violation. Defendant appealed, arguing, inter alia, that evidence obtained from the search of a vehicle should have been suppressed because it was obtained from an illegal search and seizure. The Supreme Court affirmed, holding (1) Defendant lacked standing to contest the legality of the search of the vehicle; (2) even assuming the police illegally obtained the evidence, the exclusionary rule did not apply at Defendant’s probation revocation hearing; and (3) the hearing justice did not act arbitrarily or capriciously in finding that Defendant violated his probation. View "State v. Ditren" on Justia Law

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

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

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

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

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

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

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

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