Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first degree child abuse for inflicting serious bodily injury on his infant daughter. Defendant appealed, asserting that his right to confrontation under the federal and state constitutions was violated when the trial justice allowed a pediatrician to testify regarding out-of-court statements made by a colleague of hers - an ophthalmologist who performed a retinal exam on the injured infant. The Supreme Court affirmed, holding (1) Defendant failed adequately to raise his constitutional argument at trial; and (2) the narrow exception to the "raise or waive" rule did not apply in this case. View "State v. Moten" on Justia Law

Defendant was convicted of one count of first-degree child molestation sexual assault and four counts of second-degree child molestation assault. Defendant subsequently filed an application for postconviction relief, alleging, inter alia, that his counsel committed prejudicial error when he provided Defendant's confidential psychiatric records to the state without Defendant's knowledge or consent. The superior court denied the application. The Supreme Court affirmed, holding (1) the disclosure and use of the psychiatric records was not enough to prejudice Defendant to the extent of undermining confidence in the outcome of the case; and (2) the postconviction relief justice did not err in concluding that trial counsel was not ineffective to a constitutional dimension for other alleged deficiencies. View "Hazard v. State" on Justia Law

After a jury trial, Defendant was convicted of multiple counts of first-degree sexual assault and second-degree sexual assault and one count of simple assault for his assault against three developmentally disabled women. The cumulative result of Defendant's sentences was life imprisonment followed by a consecutive term of sixteen years to serve. Defendant subsequently filed a motion to reduce his sentence, arguing that the sentence was disproportionate and excessive. The trial court denied Defendant's motion, explaining that the fact that each of the victims in this case was developmentally disabled was the driving force behind the sentence imposed. The Supreme Court affirmed, holding that the trial justice did not abuse his discretion in imposing this sentence and denying Defendant's motion to reduce. View "State v. Rivera" on Justia Law

Defendant entered a plea of nolo contendere to one felony count of possession of a controlled substance. Defendant complied with her conditions of probation. Defendant was subsequently charged with two misdemeanor offenses, both of which were dismissed. Defendant moved to have the records related to the two misdemeanor charges sealed and to have the law-enforcement-identification records related to those charges destroyed. The district court denied the motion, concluding that a nolo plea, followed by a sentence of probation, is considered a conviction for the purposes of the expungement statute. Defendant appealed, arguing that she was not convicted of a felony as defined by R.I. Gen. Laws 12-18-3. The Supreme Court quashed the decision of the district court, holding that, for purposes of the sealing statute, Defendant was not convicted of a felony, she met all the statutory requirements of the sealing statutes, and she was entitled to the benefits provided in those enactments. View "State v. Poulin" on Justia Law

After a jury trial, Defendant was convicted of one count of child enticement. Defendant subsequently filed a motion for a new trial, arguing that there was insufficient evidence to support a conviction on the count of child enticement. The trial justice denied the motion. Defendant subsequently filed a second motion for a new trial based on a claim of newly discovered evidence, which the trial justice also denied. At the conclusion of the hearing on Defendant's second motion for a new trial, the trial judge adjudged Defendant in contempt of court. The Supreme Court affirmed the judgment of conviction as well as the adjudication of contempt, holding (1) Defendant waived the opportunity to argue the insufficiency of the evidence before the Court; (2) the trial justice did not overlook or misconceive material evidence, nor was he otherwise clearly wrong in denying Defendant's second motion for a new trial; and (3) the trial justice did not err in summarily adjudicating Defendant in contempt. View "State v. Price" on Justia Law

After a jury trial, Defendant was convicted of carrying a firearm in a motor vehicle without a license. Defendant appealed, arguing that the trial justice erred (1) when he denied Defendant's motion to suppress a revolver and bullets that Defendant alleged were illegally seized, and (2) in denying Defendant's motion of acquittal. The Supreme Court affirmed, holding (1) the search that led to the seizure of the contested evidence was constitutionally valid, and therefore, the trial justice did not err in denying Defendant's motion to suppress; and (2) there was sufficient evidence to uphold Defendant's conviction, and therefore, the trial justice did not err when he denied Defendant's motion for a judgment of acquittal. View "State v. Santos" on Justia Law

Defendant was charged with two counts of felony assault. After a jury trial, Defendant was convicted of the lesser-included offense of simple assault and of a serious bodily injury felony assault. Defendant appealed, arguing that the trial justice erred by denying his motion for judgment of acquittal and his motion for a new trial. The Supreme Court affirmed the judgment of conviction, holding (1) there was sufficient evidence to support a conviction of felony assault, and therefore, the trial court did not err in denying Defendant's motion for a new trial; and (2) any analysis of the denial of Defendant's motion for judgment of acquittal was unnecessary. View "State v. Gaffney" on Justia Law

After a jury trial, Defendant was convicted of seven counts of simple assault. At the time of the alleged incidents, Defendant was a captain at the Rhode Island Adult Correctional Institutions (ACI). The charges leveled against Defendant related to his treatment of four ACI inmates. The Supreme Court affirmed the judgment of conviction, holding that the trial justice did not commit reversible error when he (1) denied Defendant's motion to sever his trial from that of his co-defendant; (2) granted the prosecution's motion to preclude the testimony of an inmate; (3) denied Defendant's motion for a new trial; (4) instructed the jury; and (5) allowed the prosecution to introduce certain photographs into evidence that were not disclosed during discovery, as the nondisclosure was inadvertent and did not prejudice Defendant. View "State v. Botas" on Justia Law

Defendant pled nolo contendere to breaking and entering. Over the next several years, the state filed five notices of probation violation against Defendant. The fourth notice of violation, the subject of this appeal, alleged that Defendant had violated R.I. Gen. Laws 11-8-2 by breaking and entering a residence. The sentencing magistrate revoked five years of Defendant's previous suspended sentence and retained eight years of that suspended sentence, with probation. Defendant subsequently filed a motion for modification or reduction of his sentence and a separate motion to vacate his sentence. A sentencing magistrate denied Defendant's motion. The Supreme Court granted in part and denied in part Defendant's appeal, holding (1) because Defendant had been released from prison, the issues that were raised about his admission of probation violation and the length of time that he was required to serve for violation of the conditions of his probation were moot; and (2) the sentencing magistrate erred when she calculated the time that remained on Defendant's suspended sentence and probation. Remanded. View "State v. Isom" on Justia Law

Defendants were charged with possessing marijuana with the intent to deliver it in violation of the Uniform Controlled Substances Act (CSA), manufacturing marijuana, and conspiracy to violate the CSA. Defendants moved to dismiss the criminal information as to all counts, relying on an affirmative defense and dismissal provision set forth in the Medical Marijuana Act. The superior court dismissed the criminal information, determining that Defendants lawfully possessed an authorized amount of marijuana plants and usable marijuana. The Supreme Court vacated the judgment of the superior court, holding that because, in contravention of the plain terms of the Act, no evidentiary hearing was held to show Defendants were in possession of an amount of medical marijuana that conformed to the limits set forth in the Act, the court's dismissal was premature. Remanded. View "State v. DeRobbio" on Justia Law