Justia Rhode Island Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court affirmed in part and quashed in part the judgment of the superior court granting Defendant's application for postconviction relief and vacated four criminal convictions for failure to register as a sexual offender, holding that Defendant was no longer required to register as a sex offender in Rhode Island.In 1993, Defendant entered a guilty plea to rape and abuse of a child and was later released. Thereafter, on four separate occasions, the state charged Defendant with failure to register as a sex offender, which led to Defendant's pleas of nolo contendere. Defendant subsequently sought postconviction relief arguing that he was not under an obligation to register as a sex offender at the time of the charged offenses. On remand, the trial court concluded that Defendant had no duty to register as a sex offender and vacated his convictions for failure to register. The Supreme Court quashed the portion of the judgment that vacated Defendant's convictions for his 2009 and 2010 offenses and otherwise affirmed, holding that Defendant was under no obligation to register as a sex offender in Rhode Island. View "Atryzek v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court convicting Defendant of second-degree sexual assault, breaking and entering, and disorderly conduct following a jury trial, holding that the trial justice did not err in denying Defendant's motion for a new trial.On appeal, Defendant argued that the trial justice erroneously denied his motion for judgment of acquittal on the count alleging disorderly conduct and in denying his motion for new trial on all convicted counts. The Supreme Court disagreed, holding that the trial justice properly exercised its independent judgment, did not err in analyzing the evidence presented, did not overlook or misconceive certain testimony, and articulated adequate reasons for denying Defendant's motion for a new trial based on the weight of the evidence. View "State v. Valdez" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court in favor of the Rhode Island Department of the Attorney General upholding a determination by the Sex Offender Board of Review classifying Petitioner as a Risk Level III sex offender under the Sexual Offender Registration and Community Notification Act, R.I. Gen. Laws 37.1, holding that there was no error.Petitioner pled guilty to three felony counts of distributing, receiving, and possessing child pornography. After Petitioner was released from custody, the Board classified him as a high-level Level III offender. On appeal, Petitioner argued that his sex offender classification was improper because the Board "unreasonably and arbitrarily" overstated his risk level and erred by failing to disclose what material it utilized beyond risk-assessment tools to establish his level of risk. The Supreme Court affirmed, holding that Petitioner failed to show that the Board's classification of him was not in compliance with the law. View "Matteson v. R.I. Department of Attorney General" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of second-degree child molestation following a jury trial, holding that there was no abuse of discretion on the part of the trial justice with respect to the admission of testimony from a physician and from Defendant's brother-in-law.Specifically, the Supreme Court held (1) the trial justice did not commit reversible error by allowing the testimony of a physician testifying as an expert witness with respect to four statements with which Defendant took issue; and (2) Defendant's contentions with respect to the cross-examination of his brother-in-law were waived. View "State v. Benitez" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court convicting Defendant of assault with a dangerous weapon and other firearm-related counts stemming from a shooting incident, holding that the trial justice did not err in denying Defendant's motion for a new trial.On appeal, Defendant argued that the trial justice erred by overlooking or ignoring material evidence that Defendant asserted provided another person with an equal opportunity to commit the charged offenses. The Supreme Court affirmed, holding (1) there was no error in the trial justice's application of the required three-step analysis; and (2) the trial justice did not overlook or misconceive material evidence in denying Defendant's motion for a new trial. View "State v. Rego" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court convicting Defendant of simple domestic assault or battery and domestic refusal to relinquish or to damage or to obstruct telephone, holding that there was no error in the trial justice's rulings in this case.On appeal, Defendant argued that the trial court committed reversible error when it impermissibly prevented and restricted his cross-examination of the complaining witness, in violation of the Sixth Amendment. The Supreme Court affirmed, holding that, given the wide discretion afforded to trial justices in limiting the extent of cross-examination, the trial justice did not err in its challenged rulings. View "State v. Garcia" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the decision and judgment of the superior court denying Defendant's motion to correct an illegal sentence pursuant to Rule 35(a) of the Superior Court Rules of Criminal Procedure, holding that Defendant waived his argument on appeal.Defendant pled guilty to several counts related to a gang-related shooting, including first-degree murder, weapons charges, assault, and conspiracy. The trial justice sentenced Defendant to a mandatory term of life imprisonment for first-degree murder, fifty years' imprisonment for offenses ancillary to the shooting, and an additional consecutive ten-year term of imprisonment pursuant to the criminal street gang enhancement statute. Defendant later filed a motion to correct his sentence, asserting that the State had failed to timely notify him of its intention to pursue the criminal street gang sentencing enhancement. The trial justice denied the motion, concluding that Defendant had expressly waived his right to timely notice as part of his agreement with the State. The Supreme Court affirmed, holding that Defendant's waiver of notice under the criminal street gang enhancement statute was valid, and therefore, Defendant's motion to correct sentence was properly denied. View "State v. Briggs" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's judgment of conviction and the denial of his motion for a new trial, holding that the trial justice did not err or abuse her discretion in denying Defendant's motion for a new trial.Following a jury trial, Defendant was convicted of four counts of first-degree child molestation and sexual assault. On appeal, Defendant argued that the trial justice erred by denying his motion for a new trial because the trial justice overlooked material evidence. The Supreme Court affirmed, holding that the trial justice articulated adequate grounds for denying Defendant's motion for a new trial and that the trial justice did not overlook material evidence. View "State v. Vazquez" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed a superior court judgment of conviction for second-degree sexual assault following a 1993 jury trial and a 2019 superior court judgment adjudicating Defendant a probation violator for his failure to appear for execution of his sentence for that 1993 conviction, holding that there was no error.In 1993, a jury found Defendant guilty of one count of second-degree sexual assault and sentenced him to ten years' imprisonment. Defendant failed to appear for execution of his sentence, and a superior court clerk entered a judgment of conviction and commitment. In 2017, Defendant was arrested and extradited to Rhode Island. In 2018, a second trial justice ordered Defendant to begin serving the unsuspended portion of his original sentence. Thereafter, the State filed a notice of probation violation alleging that Defendant failed to comply with a probation condition when he failed to appear for execution of his sentence. The trial justice declared Defendant a violator of the terms of his probation and sentenced him to an additional three years' incarceration. The Supreme Court affirmed, holding that the trial justice did not err in adjudging Defendant a probation violator for his failure to appear for execution of his sentence. View "State v. Bienaime" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of voluntary manslaughter, holding that there was no error in the proceedings below.On appeal, Defendant argued that the jury erroneously rejected his claim of self-defense when it returned a verdict of guilty of voluntary manslaughter. The Supreme Court affirmed, holding (1) in its role as fact-finder, the jury was free to reject Defendant's claim of self-defense; and (2) because this issue was never before the trial justice in the context of a motion for a new trial or a motion for judgment of acquittal, the trial justice did not weigh the evidence or pass upon the credibility of witnesses. View "State v. Stevens" on Justia Law

Posted in: Criminal Law