Justia Rhode Island Supreme Court Opinion Summaries

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

After a jury trial, Appellant was convicted of two counts of first-degree child molestation and one count of second-degree child molestation. The Supreme Court affirmed the convictions on direct appeal. Appellant subsequently filed an application for postconviction relief, arguing that his trial counsel provided ineffective assistance. The trial justice denied the application, concluding that Appellant failed to establish that his counsel’s performance was deficient. The Supreme Court affirmed, holding that the trial justice did not err in finding that trial counsel performed at a high level and in thus denying Appellant’s application for postconviction relief. View "Merida v. State" on Justia Law

In 1998, Applicant was convicted of first-degree murder and conspiracy to commit first-degree murder. Applicant later filed an application for postconviction relief on the basis of ineffective assistance of counsel. In connection with his application, Applicant filed a subpoena duces tecum seeking discovery of the mental health records of Appellant, who testified as an eyewitness in Applicant's murder trial. Appellant filed a motion to quash the subpoena. The superior court denied the motion. The Supreme Court vacated the order and remanded with directions to make further factual findings, holding that the trial justice erred in ordering the release of Appellant's health care records without first conducting the necessary statutory analysis.View "DePina v. State" on Justia Law

After a jury trial, Defendant was convicted of assault with a dangerous weapon, carrying a pistol without a license, and using a firearm while committing a crime of violence. Defendant filed a motion for a new trial, arguing that the trial justice erred by accepting certain testimony. The trial justice denied Defendant's motion. Defendant appealed, contending that the trial justice overlooked and misconceived material evidence when denying his motion for a new trial. The Supreme Court affirmed, holding that the trial justice articulated adequate grounds for denying Defendant's motion and did not overlook or misconceive material evidence when making his decision.View "State v. Baker" on Justia Law

In 1990, Defendant pled nolo contendere to twenty-six offenses, including arson and a number of robberies. Defendant was sentenced to forty years' incarceration with twenty-eight years suspended, with probation, on the one arson and eight robbery charges. In 2011, a probation violation hearing was held based upon allegations of sexual assault. Thirteen witnesses testified during the hearing regarding the allegations. The superior court subsequently found Defendant to be in violation of the terms of his probation and sentenced him to serve the previously imposed suspended sentences. The Supreme Court affirmed, holding that the hearing justice's credibility findings were not arbitrary or capricious.View "State v. Raso" on Justia Law

Defendant was charged with several crimes in connection with a drive-by shooting. After a jury trial, Defendant was convicted of carrying a firearm in a motor vehicle without a license and attempting to elude a police officer. Defendant filed a motion for a new trial with respect to both convictions. The trial justice granted the motion on the charge of attempting to elude a police officer but denied the motion with respect to the firearm charge. The Supreme Court affirmed the superior court’s judgment of conviction, holding that the trial justice did not err in denying Defendant’s motion for a new trial with respect to the charge of carrying a firearm in a motor vehicle without a license. View "State v. Nabe" on Justia Law

After a jury trial, Defendant was found guilty of six counts of first-degree sexual assault and four counts of second-degree sexual assault stemming from his unlawful conduct with his girlfriend’s daughter. Defendant was sentenced to fifty years, with twenty-five years suspended, with probation. The Supreme Court affirmed, holding that the trial justice (1) did not err in admitting evidence concerning prior acts of misconduct committed by Defendant against the complainant, including “play fighting” evidence and corporal punishment evidence; (2) did not err by allowing an examining physician to testify to statements made by the complainant during the course of her treatment; and (3) did not err by denying Defendant’s motion for a new trial. View "State v. Watkins" on Justia Law

Defendant was charged with several counts of first-degree child molestation and second-degree child molestation stemming from Defendant's unlawful conduct with the niece of his girlfriend. The case proceeded to trial. During the redirect-examination of the complaining witness, the trial justice admitted into evidence some nonspecific testimony about previous, uncharged acts of sexual misconduct. The jury eventually convicted Defendant of two counts of first-degree child molestation and three counts of second-degree child molestation. Defendant appealed, challenging the trial justice’s admission of the testimony about prior bad acts. The Supreme Court affirmed, holding that the trial justice did not abuse her discretion when she permitted the complaining witness to testify about other nonspecific evidence of prior bad acts. View "State v. Acevedo" on Justia Law

In 1998 after a plea hearing, the hearing justice accepted Amadeu Santos’s plea of nolo contendere to three counts of second-degree sexual assault. In 2012, Santos filed an application for postconviction relief, asserting that the 1998 plea colloquy did not comply with the Superior Court Rules of Criminal Procedure. The hearing justice denied Santos’s application, finding that it was barred by the doctrine of laches. The Supreme Court affirmed, holding that the hearing justice’s decision regarding the unreasonableness of Santos’s delay was not clearly wrong, nor did it constitute an abuse of discretion. View "Santos v. State" on Justia Law