Justia Rhode Island Supreme Court Opinion Summaries

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

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