Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of two counts of first-degree child molestation sexual assault. Defendant appealed, contending, among other things, that the trial justice erred when it denied his motion to suppress statements made to police during a post-arrest interrogation. The Supreme Court (1) affirmed the trial justice’s denial of Defendant’s motion for a new trial and discerned no error arising from the justice’s evidentiary rulings; but (2) remanded the case to the superior court with directions to make additional findings of fact and credibility determinations concerning the voluntariness of Defendant’s confessions, as the trial justice failed to make the findings of fact and credibility determinations essential to support his ultimate finding of voluntariness. View "State v. Bojang" on Justia Law

In 1994, Defendant was charged with felony assault with a dangerous weapon (Count One) and willful or malicious injury to property (Count Two). Count One was dismissed in consideration of Defendant pleading nolo contendere to Count Two. In 2004, Defendant filed a motion to seal with respect to both counts. A justice of the superior court denied the motion. Defendant appealed the hearing justice’s denial of her motion with respect to Count One. The Supreme Court affirmed, holding that the hearing justice did not err when she denied Defendant’s motion to seal Count One pursuant to R.I. Gen. Laws 12-1-12.1(a) because Defendant had not been exonerated of all counts in the criminal case.View "State v. Diamante" on Justia Law

After a jury trial, Defendant was convicted of one count of first-degree child molestation and three counts of second-degree child molestation. On appeal, Defendant argued that the trial justice abused her discretion in refusing to exclude all evidence of uncharged acts of molestation and that the trial justice erred in denying Defendant’s motion for judgment of acquittal and Defendant's motion for a new trial. The Supreme Court affirmed, holding (1) Defendant’s first argument was not preserved for appeal; and (2) the trial justice did not err in denying Defendant’s motions for judgment of acquittal and a new trial. View "State v. Buchanan" on Justia Law

After a jury trial, Defendant was convicted of second-degree child molestation sexual assault. Defendant appealed, arguing that the trial justice erred when she allowed the State to elicit testimony from the complaining witness, which Defendant alleged violated Sup. Ct. R. Crim. P. 16 because the testimony was contrary to the State’s supplemental discovery responses. The Supreme Court affirmed the judgment of the superior court because the content of and the inconsistency among the complaining witness’s statements was disclosed to Defendant and was a proper subject for cross-examination. View "State v. Santiago" on Justia Law

Defendant and the complaining witness (Complainant) lived together while Defendant maintained his own apartment. Due to certain incidents between Defendant and Complainant, Defendant was convicted after a jury trial of one count of simple domestic assault. Defendant appealed, arguing that the trial justice erred in denying his motion for acquittal and in denying his motion for a new trial because the evidence presented at trial did not establish that Defendant and Complainant were in a domestic relationship, as required under R.I. Gen. Laws 12-29-2. The Supreme Court affirmed the judgment of conviction, holding that the trial justice properly found Defendant and Complainant were in a domestic relationship.View "State v. Fleck" on Justia Law

After a jury trial, Defendant was convicted of four counts of first-degree sexual assault and one count of felony assault and battery for his brutal attack of a sixteen-year-old girl. Two years after the attack, law enforcement performed a buccal swab on Defendant, which matched the profile developed from a sample taken from the victim’s underwear. As a result, Defendant was indicted on seven felony counts. The Supreme Court affirmed the judgment, holding (1) the trial justice did not err in denying Defendant’s motion for judgment of acquittal based on the sufficiency of the evidence and Defendant’s motion for a new trial based on alleged errors occurring at trial; and (2) the trial justice did not err in denying Defendant’s motion to exclude the testimony of a forensic evidence analyst who testified at trial. View "State v. Nickerson" on Justia Law

After a jury trial, Defendant was convicted of two counts of assault with a dangerous weapon and one count of simple assault. On appeal, Defendant argued, among other things, that the prosecutor improperly vouched for the credibility of two witnesses during her closing argument. The Supreme Court affirmed the convictions, holding (1) the trial justice did not abuse his discretion by allowing the state to impeach Defendant’s credibility with his fourteen prior criminal convictions; and (2) although a portion of the prosecutor’s closing argument was akin to vouching, the trial justice did not err by refusing to pass the case. View "State v. Whitfield" on Justia Law

After a jury trial, Defendant was found guilty of two counts of second-degree child molestation sexual assault. The Supreme Court affirmed the superior court’s judgment of conviction and its denial of Defendant’s motion for a new trial, holding (1) the trial justice did not abuse his discretion in denying Defendant’s motion to pass the case after the prosecutor engaged in an improper line of questioning to a witness, as any prejudice which may have resulted was cured by the trial justice’s instruction to the jury; and (2) the trial justice did not misconceive or overlook material testimony and did not otherwise commit clear error in denying Defendant’s motion for a new trial. View "State v. Hie" on Justia Law

In 1990, Applicant was convicted of one count of first-degree sexual assault. In 2001, Applicant filed a pro se application for postconviction relief, alleging ineffective assistance of counsel and trial error. In 2005, the hearing justice denied the application. The Supreme Court affirmed, holding that the hearing justice properly did not commit clear error or misconceive material evidence in rendering his decision, as (1) Applicant’s claims relating to alleged errors committed by the trial justice were barred by the doctrine of res judicata; and (2) Applicant failed to show to his trial counsel’s representation fell below an objective standard of reasonableness. View "Lamoureux v. State" on Justia Law

Defendant pled nolo contendere to three counts of second-degree child molestation. Before he was sentenced, Defendant filed a motion to withdraw his plea. The trial justice denied the motion and sentenced Defendant to three concurrent sentences of fifteen years at the Adult Correctional Institutions. Eighteen months after sentencing, Defendant filed a motion to vacate judgment and sentence, arguing that his plea to the criminal charges should be set aside because his attorney did not inform him that the attorney was undergoing personal struggles during his representation of Defendant. The Supreme Court affirmed, holding (1) Defendant's appeal was not properly before the court; and (2) even if Defendant's argument was properly made, the argument was without merit.View "State v. Castriotta" on Justia Law