Justia Rhode Island Supreme Court Opinion Summaries

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

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

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

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

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

In 2002, Applicant was convicted for the second-degree murder of his infant daughter. In 2007, Applicant filed an application for postconviction relief, alleging that newly discovered evidence required a new trial. At a hearing before a justice of the superior court, Applicant presented the testimony of Dr. Richard T. Callery, who, while he was employed with Rhode Island’s Office of State Medical Examiners, had reviewed the victim’s file. The hearing justice denied the application for postconviction relief, concluding that the newly discovered evidence was not material and would not change the verdict at trial. The Supreme Court affirmed, holding that the testimony of Dr. Callery did not warrant postconviction relief. View "D’Alessio v. State" on Justia Law

In January 2006, Defendant was charged with two counts of first-degree robbery and presented as a probation violator. In April 2006, Defendant was adjudicated a probation violator and began serving his previously suspended sentences for drug-related charges. Defendant was found guilty on both counts and sentenced in April 2009. Three years later, Defendant filed a motion for credit for time served, arguing that his sentence in the robbery case should have been reduced by the number of days that he spent incarcerated between his arrest and his sentencing. The trial court denied the motion. The Supreme Court affirmed in part and vacated in part the order of the superior court, holding that, pursuant to R.I. Gen. Laws 12-19-2, Defendant was entitled to a credit for the time he spent incarcerated between January 2006 and April 2006. View "State v. Wray" on Justia Law

Defendant pled guilty to second-degree murder and was sentenced to life imprisonment. This appeal concerned Defendant’s third attempt to challenge his plea and sentence with a motion to reduce or correct sentence pursuant to Rule 35 of the Superior Court Rules of Criminal Procedure. The trial justice denied the motion. Defendant appealed, arguing that his life sentence was illegal because he should have been convicted of manslaughter, which carries a maximum sentence of thirty years, and that the continued imposition of his purportedly illegal sentence constituted a violation of the Eighth Amendment to both the federal and the state Constitutions. The Supreme Court affirmed, holding that there was no error in the hearing justice’s decision to deny the Rule 35 motion and that Defendant’s constitutional arguments had no merit. View "State v. Miguel" on Justia Law

Defendant pled nolo contendere to second degree robbery and was sentenced to a term of incarceration with eight and one-half years suspended, with probation. The state later filed a violation notice against Defendant for allegedly violating the terms of her probation. A hearing justice found that Defendant had violated the conditions of her probation by failing to keep the peace and maintain good behavior and imposed the previously suspended sentence. The Supreme Court affirmed, holding that the hearing justice did not abuse his discretion in executing the remaining eight and one-half years of Defendant’s previously suspended sentence. View "State v. McKinnon-Conneally" on Justia Law

In the town of Tiverton, two police officers from the Little Compton police department had a discussion with Defendant about a motor-vehicle accident that occurred in Little Compton. The officers then transported Defendant in a police cruiser back to the scene of the accident, where they administered field-sobriety tests, which Defendant failed. Defendant was subsequently charged with driving under the influence of liquor or drugs, among other offenses. Defendant filed a motion to dismiss due to an unlawful arrest, arguing that the officers lacked the authority to arrest him in Tiverton. The trial judge concluded that the arrest was unlawful and dismissed the case. The Supreme Court quashed the judgment of the district court, holding that Defendant was not arrested by the Little Compton police while they were in Tiverton, and therefore, the trial judge erred when she granted Defendant’s motion to dismiss. Remanded.View "State ex rel. Town of Little Compton v. Simmons" on Justia Law