Justia Rhode Island Supreme Court Opinion Summaries

Defendant Jeffrey Murray was charged by criminal information with a felony pursuant to R.I. Gen. Laws 12-29-5 for violating a no-contact order. Defendant pleaded nolo contendere to the charges and was sentenced under the terms of section 12-29-5. Defendant subsequently filed a motion to correct sentence, arguing that the sentence imposed on him was illegal because, in his view, the provisions of section 12-29-5 applied only to individuals with two prior misdemeanor convictions, and one of his predicate offenses was a felony. The superior court denied Defendant's motion, ruling that the provisions of section 12-29-5 did apply because Defendant had been convicted of two prior domestic violence offenses, and the statute did not distinguish between misdemeanors and felonies. The Supreme Court affirmed, holding (1) Defendant's argument was not an attack on the legality of his sentence, but rather on the propriety of his conviction, and Defendant unequivocally waived all nonjurisdictional defects in the criminal information by virtue of his decision to enter a plea of nolo contendere; and (2) the sentence in this case was not illegal because it was within the prescribed statutory limits. View "State v. Murray" on Justia Law

Gary Tassone was convicted of murder and sentenced to life imprisonment without the possibility of parole. Tassone subsequently filed an application for postconviction relief, alleging that his constitutional rights had been adversely impacted by the ineffective assistance of counsel and by witness perjury. The superior court denied the application without conducting an evidentiary hearing. The Supreme Court vacated the judgment of the superior court, holding that, from this point forward, an evidentiary hearing is required in the first application for postconviction relief in all cases involving applicants sentenced to life without the possibility of parole. Remanded for an evidentiary hearing. View "Tassone v. State" on Justia Law

Defendant Shurron Washington sought review of an adjudication of a probation violation after a hearing. At the conclusion of the hearing, the hearing justice found that Defendant had violated the terms and conditions of his probation, and the hearing justice revoked the suspension of a ten-year sentence that had previously been meted out. On appeal, Defendant contended that the hearing justice erred in adjudicating him to be a probation violator because, in Defendant's view, the record raised "too many questions" about the reliability of the identification of him as the perpetrator of an alleged attack. The Supreme Court affirmed, holding that the hearing justice did not act arbitrarily or capriciously when he declared that Defendant had violated the terms and conditions of his probation. View "State v. Washington" on Justia Law

Defendant Esteban Carpio was convicted of first-degree murder of a police officer, discharging a firearm while committing a crime of violence, and felony assault with a dangerous weapon. The superior court sentenced Defendant to life imprisonment without the possibility of parole, a consecutive sentence of life imprisonment for committing a crime of violence with a firearm resulting in death, and another consecutive twenty-year term for felony assault on an elderly woman. The Supreme Court dismissed Defendant's appeal and affirmed the superior court, holding (1) the evidence presented at trial was sufficient to sustain Defendant's conviction; (2) the trial justice properly instructed the jury on the question of criminal responsibility; and (3) the trial court did not err in sentencing Defendant to life imprisonment without the possibility of parole. View "State v. Carpio" on Justia Law

Following a jury trial, Defendant Kayborn Brown was convicted of first-degree robbery and sentenced to forty years' incarceration. The Supreme Court affirmed the judgment of conviction, holding that the trial justice (1) did not err in denying Defendant's motion to suppress complainant's out-of-court identification from a photographic array, as the identification was not impermissibly suggestive or improperly tainted; and (2) did not abuse its discretion under R.I. R. Evid. 403 by denying Defendant's motion in limine to exclude evidence of a fraudulent charge to the complainant's credit card that occurred shortly after the robbery, as the evidence connected Defendant to the crime. View "State v. Brown" on Justia Law

Kevin Lyons was convicted of two counts of first-degree child molestation. The Supreme Court affirmed. Lyons subsequently filed an application for postconviction relief, arguing that he had been prejudiced by ineffective assistance of counsel. The superior court denied the application, and the Supreme Court affirmed. Lyons then filed a second application for postconviction relief, relying on an array of arguments. The superior court denied Lyons' second application, finding that each of Lyons' claims either lacked merit or were barred by the doctrine of res judicata. The Supreme Court affirmed, holding that Lyons failed to carry his burden of proving, by a preponderance of the evidence, that postconviction relief was warranted. View "Lyons v. State" on Justia Law

A jury found Applicant Rudy Sifuentes guilty of first-degree murder in a manner involving torture and aggravated battery, for which he was sentenced to life imprisonment. Applicant subsequently filed a pro se application for postconviction relief, alleging ineffective assistance of counsel and a violation of his constitutional rights. The superior court denied Applicant's application. Applicant appealed, arguing that the hearing justice erred in denying his application by accepting "the memoranda of investigating counsel in lieu of evidence." The Supreme Court affirmed, holding that under the circumstances, the hearing justice properly adequately followed the procedures set forth in Rhode Island's Postconviction Remedy Statute and properly denied Applicant's postconviction-relief application. View "Sifuentes v. State" on Justia Law

Defendant Gary Gromkiewicz entered a plea of nolo contendere to one count of first-degree robbery and was sentenced to twenty years incarceration, thirteen years suspended with probation. The superior court subsequently adjudged Defendant to be in violation of his probation. Defendant appealed, arguing that the trial justice erred by finding that he had violated his probation by failing to keep the peace and remain on good behavior. The Supreme Court affirmed, holding that the trial justice acted well within her discretion when she assessed the credibility of the testifying witnesses and did not act arbitrarily or capriciously in finding that Defendant violated the terms of his probation. View "State v. Gromkiewicz" on Justia Law

This appeal concerned the 2003 fire that occurred at the Station nightclub, wherein one hundred people died. The nightclub was co-owned by Plaintiffs, Michael and Jeffrey Derderian. A grand jury returned separate criminal indictments against Plaintiffs on charges of involuntary manslaughter. Prior to the fire, Essex Insurance Company had issued an insurance policy to Michael. Plaintiffs demanded, pursuant to R.I. Gen. Laws 12-28-5 and the policy, that Essex afford them a defense against the criminal prosecutions. When Essex refused, Plaintiffs filed a complaint against Essex, seeking a declaratory judgment that the grand jury indictments against them constituted a suit as defined in the Essex policy and that, accordingly, Essex had a duty to provide them with a defense in the related criminal proceedings. The superior court granted summary judgment in favor of Essex. The Supreme Court affirmed, holding that the language of the policy clearly showed that the parties' intention when entering into the contract was that Essex would provide Plaintiffs with a defense only in civil proceedings in which bodily injury or property damage were alleged, and therefore, Essex had no duty to defend Plaintiffs in their criminal prosecutions. View "Derderian v. Essex Ins. Co." on Justia Law

After a jury trial, Wesley Spratt was found guilty of murder while committing or attempting to commit robbery, first-degree robbery, carrying a pistol without a license, and committing a crime of violence while armed with a firearm. The Supreme Court affirmed the convictions. Spratt subsequently filed a petition for postconviction relief. The superior court eventually denied the petition after a hearing on the merits. The Supreme Court affirmed, holding (1) the hearing justice did not err in finding that Spratt's contention that a courthouse identification of Spratt by a witness was improperly orchestrated by the state was without merit; (2) Spratt did not meet his burden of showing sufficient evidence of the State's alleged coercion of the witness; (3) Spratt did not meet his burden of showing that any discovery violation occurred; (4) the hearing justice correctly rejected Spratt's claim of unlawful sentencing; (5) Spratt's allegations of ineffective assistance of counsel were unavailing; and (6) the hearing justice did not err in finding that the evidence presented at trial was sufficient to convict Spratt. View "Spratt v. State" on Justia Law