Justia Rhode Island Supreme Court Opinion Summaries

Defendant Raymond McWilliams was found guilty on one count of first-degree robbery and one count of assault with a dangerous weapon. In light of his "impressive" criminal history, the trial justice sentenced him to life in prison for first-degree robbery, to be served consecutively to eleven-and-one-half years that previously had been executed because he violated probation on a previously imposed sentence on a prior second-degree murder conviction. Defendant was also sentenced to life in prison for the conviction for assault with a dangerous weapon, to be served consecutively to the sentence imposed for the robbery and the previously imposed probation-violation sentence. Because he qualified as a habitual offender the trial justice imposed an additional ten years imprisonment to run consecutively to the previously imposed sentences. On appeal to the Supreme Court, Defendant asserted that the trial justice erred by: (1) providing a supplemental jury instruction that contradicted Rhode Island law; (2) refusing to recuse from presiding as the trial justice because of comments he had made during a joint probation-violation hearing and bail hearing; (3) admitting into evidence defendant's prior conviction for second-degree murder; (4) denying his motion for acquittal; and (5) denying his motion for a new trial. After review, the Court concluded that Defendant's arguments were without merit, and affirmed the judgment of the Superior Court. View "Rhode Island v. McWilliams" on Justia Law

In early 2008, over the course of a lengthy jury trial, the state presented approximately thirty witnesses, including known criminals, against Defendant Michael Ciresi who was once a decorated North Providence police officer. Defendant was charged with multiple counts ranging from the receipt of stolen goods to burglary. Ultimately Defendant was convicted on all but one of the counts with which he was charged. Defendant appealed his convictions, contending that the trial justice abused his discretion by admitting numerous instances of Defendant's uncharged misconduct under Rule 404(b) of the Rhode Island Rules of Evidence. Defendant also challenges the trial justice's decision to allow the joinder of two separate indictments against him, as well as the trial justice's subsequent denial of his motion to sever the indictments for trial. Upon review, the Supreme Court affirmed the judgments of the Superior Court: "[b]ased on the defendant's failure to demonstrate any basis upon which [the Court] might conclude that he suffered prejudice arising from the consolidation of the indictments against him for trial," the Court held that the trial justice's joinder and denial of Defendant's motion to sever did not prejudice his constitutional right to a fair trial. The Court found no abuse of discretion on the part of the trial justice and affirmed his rulings. View "Rhode Island v. Ciresi" on Justia Law

Applicant David Higham appealed a superior court judgment that denied his second application for postconviction relief. In 2000, a jury found that Applicant committed two acts of first-degree child molestation against the seven-year-old daughter of his step son. Applicant was sentenced to concurrent terms of forty years on each count with twenty years to serve and twenty suspended with probation. In 2006, Applicant filed a pro se application for postconviction relief alleging ineffective assistance of counsel. Counsel was appointed to represent him, but counsel later withdrew, noting in his motion that Applicant's application was "wholly frivolous" and without merit. Even though the motion to withdraw was pending, counsel appeared with applicant at a hearing in Superior Court. At the conclusion of the hearing, a stipulation, signed by both applicant and his attorney was entered on December 5, 2008. The stipulation provided that the motion for postconviction relief would be dismissed with prejudice in exchange for a reduction in sentence approved by the hearing justice. In 2009, Applicatn appeared before the parole board seeking early release. The board denied his but because he refused to acknowledge his crime or complete a sex-offender-treatment program. Applicant then filed another pro se application for postconviction relief, alleging that parole had been unlawfully denied; jury misconduct, and that he was actually innocent. Finding that none of the issues raised on appeal had merit, the Supreme Court affirmed the superior court's denial of Applicant's application for postconviction relief. View "Higham v. Rhode Island" on Justia Law

Applicant Randy Anderson appealed a Superior Court judgment that dismissed his application for post-conviction relief. On appeal, Applicant contended that the hearing justice erred by (1) deeming his claim of prosecutorial misconduct to be procedurally barred; (2) finding no discovery violation on the part of the state for failing to produce certain medical records; and (3) determining that the medical records would have been “of little or no value to the factfinder in the context of [Anderson’s] trial.” This case came before the Supreme Court for oral argument on January 24, 2012, pursuant to an order directing the parties to appear and show cause why the issues raised in this appeal should not be summarily decided. After carefully considering the written and oral submissions of the parties, we are satisfied that this appeal may be resolved without further briefing or argument. Finding no error with the hearing justice's decisions, the Supreme Court affirmed the Superior Court's judgment. View "Anderson v. Rhode Island" on Justia Law

On October 31, 2004, three-year-old Thomas J. Wright died as a result of extensive injuries that tragically had been inflicted upon him by his aunt and her boyfriend after they returned home from a night of drinking. Defendant Katherine Bunnell was convicted by a jury of second-degree murder and of conspiracy to commit the offense of murder. As a result, she was sentenced to consecutive terms of life imprisonment at the Adult Correctional Institutions (ACI) for the murder conviction and ten years to serve at the ACI for the conspiracy conviction. Defendant appealed her conviction on two grounds: (1) that the trial justice erred by excluding from evidence certain portions of an interview given by her boyfriend, Gilbert Delestre, at the Woonsocket Police Department the day before TJ died; and (2) the trial justice erred in denying her motion for a new trial. Finding no error in the trial justice's decisions, the Supreme Court affirmed Defendant's conviction. View "Rhode Island v. Bunnell" on Justia Law

Defendant Jeffrey Alston (alias John Doe) appealed his conviction for conspiracy to break and enter, breaking and entering of a dwelling, and assault with a dangerous weapon. He also appealed the denial of his motions for a new trial. On appeal, Defendant contended that his right to confrontation under the United States and Rhode Island Constitutions was violated by the evidentiary rulings of the trial justice, that his right to cross-examine one of the state’s witnesses was unduly restricted, and that the trial justice erred in refusing to pass the case. Upon review, the Supreme Court affirmed the Superior Court's judgment. View "Rhode Island v. Alston" on Justia Law

Defendant Hamlet M. Lopez appealed a Superior Court judgment of conviction for first-degree murder, for which he received a sentence of life imprisonment without the possibility of parole. On appeal, Defendant argued that the trial justice erred by (1) allowing DNA evidence to be introduced against him through the testimony of a laboratory supervisor and the admission of an allele table documenting the DNA profiles of the defendant and the decedent; (2) admitting evidence of his prior instances of violence; (3) failing to instruct the jury adequately about prior inconsistent statements; and (4) imposing a sentence of life imprisonment without the possibility of parole. Upon review, the Supreme Court affirmed the Superior Court's judgment. View "Rhode Island v. Lopez" on Justia Law

On August 27, 2007, an eighty-seven-year-old woman's purse was stolen in a supermarket parking lot. As a result, Defendant Nelson Rolon was charged with and ultimately convicted of first-degree robbery. Rolon appealed, arguing that the trial justice erred in denying his motion for a judgment of acquittal because the evidence produced at trial was legally insufficient to prove the element of force. The Supreme Court affirmed, holding (1) the State produced sufficient evidence from which a jury could infer beyond a reasonable doubt that Defendant used force to take the victim's purse; and (2) therefore, sufficient evidence existed that would justify a reasonable juror in finding that Defendant robbed the victim on August 27, 2007. View "State v. Rolon" on Justia Law

Plaintiff Nicola Tarzia was arrested and charged with possession of cocaine. After Tarzia successfully completed a diversion program, the State dismissed the charge. Tarzia later filed a motion to expunge the charge, which the district court granted. Later, however, Tarzia's past criminal activity was subsequently published. Tarzia filed a fifteen-count civil action against several State and City actors, alleging, inter alia, unlawful dissemination of expunged records, negligence, and failure to seal Plaintiff's records. The circuit court dismissed two counts for failure to state a claim upon which relief can be granted, and after a jury trial, granted judgment as a matter of law to the State and City. The Supreme Court affirmed, holding (1) the remedy of civil liability did not apply to Tarzia's case; (2) there was no reason for the Court to recognize other causes of action based in common law for alleged violations of the sealing statute; (3) the information allegedly provided to a newspaper reporter did not amount to a violation of the state's right-to-privacy statute; and (4) Tarzia waived his right to challenge on appeal the district court's finding that all of the named defendants were sued in their official capacity. View "Tarzia v. State" on Justia Law

After a jury trial, Defendant Emmanuel Barbosa was found guilty of felony assault, carrying a pistol without a license, and possession of a firearm after previous conviction of a crime of violence. The Supreme Court affirmed Defendant's conviction. Defendant subsequently filed an application for postconviction relief, arguing that his counsel was ineffective. The superior court denied the application. The Supreme Court affirmed, holding that the hearing justice made adequate findings of fact and did not overlook or misconceive material evidence in finding that Defendant failed to prove to a reasonable probability that he was prejudiced by his trial counsel's purported deficiencies. View "Barbosa v. State" on Justia Law