Justia Rhode Island Supreme Court Opinion Summaries

Defendant was charged by information with threatening a public official with bodily harm as a result of the lawful performance of his official duties. The superior court dismissed the information for lack of probable cause, finding that, based on the contents of the information package, the state would not be able to prove beyond a reasonable doubt that Defendant's statements constituted a threat of bodily harm to a public official in the performance of his public duties. The Supreme Court affirmed, holding that there was no evidence in the record of probable cause to support the charge, and accordingly, the motion justice did not err in dismissing the information. View "State v. Baillargeron" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and three firearms charges. The Supreme Court affirmed Defendant's convictions on all counts. Defendant subsequently filed an application for postconviction relief, alleging ineffective assistance of counsel. The superior court denied Defendant's application. The Supreme Court affirmed, holding that the trial court did not err in concluding (1) trial counsel did not have an actual conflict of interest during Defendant's representation that adversely affected the lawyers' performance; and (2) Defendant's attorneys did not render ineffective assistance in choosing not to pursue a motion to suppress evidence or to mount a third-party perpetrator defense. View "Rivera v. State" on Justia Law

After a jury trial, Defendant was sentenced to life imprisonment for the first-degree murder of his mother. Defendant subsequently filed an application for postconviction relief. The superior court appointed counsel to represent Defendant in connection with his application, but counsel determined that the issues raised in the application were frivolous and without merit and moved to withdraw as attorney of record. After a hearing and a finding that Defendant's arguments were meritless, the hearing justice granted the motion. The hearing justice then denied and dismissed Defendant's application. The Supreme Court affirmed, holding that the hearing justice did not err in (1) granting counsel's motion to withdraw, as all of the procedural requirements of Shatney v. State were followed; and (2) denying Defendant's application after giving Defendant ample opportunity to respond to the proposed dismissal of his application. View "Perez v. State" on Justia Law

Defendant entered pleas of nolo contendere to three counts of second-degree child molestation, and the hearing justice accepted Defendant's plea. Five months later, Defendant filed an application for postconviction relief, claiming that his conviction should be vacated because his plea was involuntary and because he had been denied his right to the effective assistance of counsel. The superior court dismissed Defendant's application. The Supreme Court affirmed, holding (1) Defendant voluntarily pleaded to the charges; (2) Defendant's attorney did not render ineffective assistance in pressuring him to plead to the charges or in failing to advise Defendant to inform the court that he had ingested prescription medication during the plea hearing; and (3) the hearing justice did not err in failing to draw an adverse inference against the state based on its failure to call upon Defendant's plea attorney to testify at the postconviction-relief hearing. View "Jolly v. Wall" on Justia Law

Defendant entered an Alford plea to two counts of second-degree child molestation. Seventeen years later, Defendant filed an application for postconviction relief, arguing that there was not sufficient evidence for the trial justice to support a conclusion that Defendant understood both the nature of the charges and the consequence of the plea, and thus, the plea was not made voluntarily and intelligently. The superior court denied the application. The Supreme Court affirmed, holding that there was no basis to vacate Defendant's plea, as Defendant's plea was voluntary, intelligent, and knowing, and Defendant was well aware of the nature of the charges against him at the time he pleaded to them. View "Camacho v. State" on Justia Law

In 1992, Defendant pleaded nolo contendere several charges, including first- and second-degree child molestation. Defendant was sentenced to thirty years on each of the molestation counts, with fifteen years to serve, fifteen years suspended, with probation. Defendant was later convicted of residential burglary and adjudicated a probation violator in 2004. After a probation-revocation hearing, the superior court stayed the execution of ten years of Defendant's previously suspended sentence. In 2009, Defendant admitted to a probation violation. In 2010, Defendant filed a motion to correct the 2004 sentence, arguing that the trial justice was without authority to impose a stayed sentence. The trial court granted in part Defendant's motion and vacated the 2004 sentence. The trial justice then resentenced Defendant. Defendant appealed, arguing that the 2004 was no longer a viable sentence, such that Defendant was improperly adjudged to be a probation violator in 2009, and that the trial justice impermissibly resentenced him. The Supreme Court affirmed, holding (1) the trial justice's error in staying the execution of the ten years remaining on the previously suspended sentence did not vitiate that portion of the sentence that the original sentencing justice had imposed; and (2) the trial justice correctly resentenced Defendant. View "State v. Roberts" on Justia Law

After a jury trial, Defendant was convicted of three counts of first-degree child molestation and three counts of second-degree child molestation. Defendant appealed, arguing that the trial justice's denial of his motion for a new trial was clearly erroneous because the jury's verdict was against the weight of the evidence and failed to do substantial justice. Specifically, Defendant argued that the testimony of the complaining witness lacked credibility. The Supreme Court affirmed, holding (1) the trial justice performed an exhaustive review of the testimony presented at trial and thoughtfully evaluated the evidence and credibility of the witnesses; and (2) the trial justice's findings and conclusions in denying Defendant's motion for a new trial were well within his discretion. View "State v. LaPierre" on Justia Law

Defendant was convicted of possession of cocaine with the intent to deliver and possession of cocaine in an amount between one ounce and one kilogram. In his appeal, Defendant challenged the denial of his motion to suppress evidence seized from his home, arguing that the affidavit underlying the warrant did not provide the requisite probable cause to support a search of his residence. The Supreme Court affirmed, holding (1) the totality of the circumstances presented within the affidavit was sufficient to enable the magistrate to reasonably infer that illegal contraband would be found in Defendant's residence; and (2) the trial justice did not err in determining that the confidential informant's tip was properly corroborated or that this corroborated tip, combined with Defendant's recent sale of cocaine in a controlled buy, satisfied the probable cause requirement to support the warrant authorizing the search of Defendant's residence. View "State v. Cosme" on Justia Law

After Shelley Tyre died, her parents brought a wrongful-death action against Shelley's husband, David Swain, alleging that he caused Shelley's wrongful death, that he was a slayer pursuant to R.I. Gen. Laws 33-1.1-1(3), and he should be subject to civil liability for a criminal act. After a jury trial, the court found in favor of Shelley's parents on all three counts. The probate judge later issued an order declaring that neither Swain, nor his heirs at law, should receive directly or indirectly from Shelley's estate pursuant to the Rhode Island Slayer's Act. Accordingly, Plaintiffs, David's children and Shelley's stepchildren, were precluded from inhering under Shelley's will as contingent beneficiaries because this inheritance would confer a benefit on their father. The Supreme Court affirmed, holding that Plaintiffs' taking under Shelley's will would unquestionably confer a benefit upon David, in direct contravention of the Slayer's Act. View "Swain v. Estate of Tyre" on Justia Law

Defendant was convicted of violating his probation. The superior court executed thirty months of Defendant's previously imposed suspended sentence. The Supreme Court affirmed the judgment of the superior court, holding (1) Defendant waived his argument for appeal that the hearing justice properly refused to admit a letter written and sent to him by the State's complaining witness; (2) the hearing justice did not abuse its discretion in limiting testimony concerning past arguments between Defendant and the complaining witness about the complaining witness's drug use and whether the complaining witness had bought him drugs when he was in a drug-treatment program; and (3) the hearing justice did not act arbitrarily and capriciously in finding a violation. View "State v. Ford" on Justia Law