Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of simple assault and disorderly conduct. The Supreme Court affirmed, holding that the superior court did not commit reversible error in refusing to (1) holding a posttrial evidentiary hearing to determine if the jury was racially biased or if certain juror misconduct had occurred; (2) permit the all fifteen jurors who heard the evidence to be seated on the deliberating panel, as no more than twelve jurors may be seated unless both parties agree; and (3) instruct the jury that aggressive actions of the police could constitute a defense to the charge of disorderly conduct. View "State v. Brown" on Justia Law

The director of the Department of Mental Health, Retardation and Hospitals (Department) petitioned the superior court for an emergency transfer of Irving Briggs, a sentenced inmate, from the forensic unit of the Eleanor Slater Hospital, where Briggs was receiving mental-health services, back to the Adult Correctional Institutions (ACI) where he had previously been incarcerated. The superior court allowed an emergency transfer in the absence of a full evidentiary hearing, finding that potential harm could occur to others if Briggs were to remain at the forensic unit. After a post-transfer evidentiary hearing, a mental health advocate filed a motion to impose sanctions, alleging that the Department contrived a materially inaccurate set of facts to secure an immediate discharge of Briggs from the hospital. The trial justice declined to find a conspiracy among the Department staff and administration to remove Briggs from the forensic unit at any and all costs. The Supreme Court affirmed, holding (1) the trial justice did not abuse his discretion when it denied to impose sanctions; and (2) Briggs's argument that his emergency transfer to the ACI violated his procedural due process rights was moot. View "In re Briggs" on Justia Law

Defendant pled guilty to eight felony counts relating to his unethical conduct as a member of the town council. On the day of his sentencing, the U.S. district court entered an order of forfeiture requiring Defendant to forfeit $46,000 to the federal government, representing the bribe money Defendant received to perform official acts as town council member. While Defendant was employed, he had contributed $30,554 to the Employees' Retirement System of Rhode Island (ERSRI). While a member of the town council, Defendant had contributed $5,490 to the Municipal Employees' Retirement System (MERS). Both ERSRI and MERS were administered by the Retirement Board of ERSRI (Board). After the Board refused to refund Defendant's contributions to ERSRI, Defendant filed a complaint against the Board, contending that the Board was obligated to return his contributions to him. The trial justice (1) revoked Defendant's MERS pension in its entirety, and (2) ordered the Board to return to Defendant the contributions he had made to ERSRI. The Supreme Court affirmed, holding that, because the federal court issued neither a judgment nor an order of restitution against Defendant, the Board had no statutory basis upon which it could refuse Defendant's demand for a return of his contributions. View "Zambarano v. Ret. Bd. of Employees' Ret. Sys. of R.I." on Justia Law

In 2002, Defendant pleaded guilty to several criminal offenses and was sentenced to a term of probation. In 2009, Defendant was adjudged to be in violation of his probation. The superior court subsequently executed six years of Defendant's previously imposed sentence. Defendant appealed, challenging the sufficiency of the evidence in support of the superior court's judgment. The Supreme Court affirmed, holding that the evidence was sufficient to support the hearing justice's finding that Defendant failed to keep the peace or remain on good behavior, and thus, the hearing justice did not rule in an arbitrary or capricious manner in finding that Defendant violated the terms and conditions of his probation. View "State v. Lopes" on Justia Law

After a jury trial, Defendant was convicted of manufacturing or cultivating marijuana. The Supreme Court affirmed the conviction, holding that the trial justice (1) did not err in denying Defendant's motion for a judgment of acquittal as to the charge of manufacturing and cultivating marijuana where the evidence was legally sufficient to support the conviction; (2) did not err in denying Defendant's motion for a judgment of acquittal as to aiding or abetting the manufacture and cultivation of marijuana because the evidence supported that offense; and (3) did not err when he instructed the jury that it could convict Defendant of manufacturing or cultivating marijuana as an aider or abettor. View "State v. Long" on Justia Law

After a jury trial, Defendant was convicted of robbery in the first degree, conspiracy to commit robbery, breaking and entering a dwelling without consent while the owner was on the premises, carrying a firearm without a license, and using a firearm during the commission of a crime of violence. Defendant appealed, arguing that the trial justice erred by admitting into evidence unredacted photographs not only that portrayed his tattoos, but his face as well. The Supreme Court affirmed, holding that the trial justice did not abuse his discretion in determining that the pictures showing Defendant's face were relevant or in admitting the photographs into evidence. View "State v. Delarosa" on Justia Law

After a jury trial, Defendant was convicted of several firearm offenses, eluding a police officer, and resisting arrest. Defendant's convictions were affirmed on appeal. Defendant subsequently filed an application for postconviction relief, claiming that the jury was improperly instructed and that the trial justice erred when he permitted an alcohol, tobacco, firearms, and exposives agent to "offer to the jury an opinion on the truthfulness of a statement" Defendant made. The trial justice dismissed Defendant's application. On appeal, Defendant argued that the agent's testimony was prejudicial and not capable of being cured with a cautionary instruction and that the cautionary instruction was improper. The Supreme Court affirmed, holding that Defendant's claims were barred by res judicata because Defendant failed to raise his claims on direct appeal. View "Hall v. State" on Justia Law

After a jury trial, Defendant was convicted of several acts of child molestation and sexual assault. Defendant filed a motion for a new trial, which the trial justice denied. The Supreme Court affirmed the denial of Defendant's motion for a new trial, holding that the trial justice independently evaluated the evidence and assessed the credibility of the witnesses and did not overlook relevant and material evidence, thoroughly reviewed and summarized the testimony of the trial witnesses and issued a comprehensive decision setting forth his reasons for denying the motion for a new trial, and therefore correctly determined that credible evidence existed to support the jury's finding of guilt. View "State v. Paola" on Justia Law

In 2003, Defendant was charged with obtaining money under false pretenses. Defendant pled nolo contendere to the charge and agreed to pay restitution. Defendant's sentencing was deferred for a period of five years. In 2010, Defendant filed a motion to seal her records under R.I. Gen. Laws 12-19-19(c), arguing that under the plain language of the statute as amended in 2010, she was eligible to have her records sealed, and that if the court found that retroactivity was an issue, section 12-19-19(c) was entitled to retroactive application. The superior court denied the motion, finding that the statute was not intended to be applied retroactively. The Supreme Court affirmed, holding (1) the plaint language of section 12-19-19 as amended did not imply that the General Assembly intended for it to apply retroactively; and (2) declining to apply section 12-19-19(c) retroactively would not reach an absurd result. View "State v. Morrice" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree. The trial justice imposed a sentence of life imprisonment without the possibility of parole. Defendant appealed, contending that the trial justice committed reversible error in (1) admitting acts of prior misconduct he allegedly committed against the decedent, (2) denying his motion for a new trial, and (3) sentencing him. The Supreme Court affirmed, holding that the trial justice did not err in (1) admitting testimony relating to Defendant's acts of prior misconduct for the limited purpose of demonstrating Defendant's intent; (2) denying Defendant's motion for a new trial, as the evidence was sufficient to convicted him of first-degree murder; and (3) sentencing Defendant to life imprisonment without the possibility of parole, as any mitigating factors were far outweighed by the aggravating factors present in this case. View "State v. Martinez" on Justia Law