Justia Rhode Island Supreme Court Opinion Summaries

Defendant Windell McRae was convicted for simple domestic assault. Defendant appealed, arguing, inter alia, that a remark by complainant that Defendant had been drinking on the day of the assault was sufficiently prejudicial as to prevent the jury from calmly and dispassionately considering the evidence. The Supreme Court affirmed the superior court, holding (1) considering the full testimonial evidence and the trial justice's specific and cautionary instruction to the jury, the trial justice did not clearly err by denying Defendant's motion to pass the case after the complainant testified about Defendant's drinking; and (2) the trial justice did not abuse his discretion in admitting, for impeachment purposes, evidence of Defendant's prior convictions. View "State v. McRae" on Justia Law

Twelve-year old Frances G. told a law enforcement officer that she threw a rock or brick against the windshield of a vehicle and carved something into the side of the vehicle. After a trial before a justice of the family court, Frances was adjudicated to be wayward. The Supreme Court affirmed, holding (1) the trial justice was not clearly wrong when she allowed the vehicle's owner to testify about what her daughter told her she saw Frances do to the car because the statement qualified as an "excited utterance" under R.I. R. Evid. 803(2); and (2) Frances knowingly and voluntarily waived her Miranda rights before speaking to the law enforcement officer, and therefore, the trial justice did not err in admitting the statement into evidence. View "In re Frances G." on Justia Law

After a jury trial, Timothy Scanlon was found guilty on six counts related to the sexual assault of a woman. The trial justice sentenced Scanlon to fifty years to serve concurrently on each of the first four counts and a suspended sentence of twenty years, with twenty years of probation on the remaining two counts. Scanlon subsequently filed a timely motion to reduce sentence. The hearing justice entered an order denying Scanlon's motion to reduce. The Supreme Court affirmed the order of the superior court, holding that the hearing justice did not abuse his discretion (1) in refusing to consider sentences that had been meted out to persons who Scanlon contended were similarly situation to him, and (2) by failing to afford Scanlon leniency in view of his family situation. View "State v. Scanlon" on Justia Law

A superior court jury found Defendant Chhoy Hak guilty of four counts of first-degree child molestation and two counts of second-degree child molestation. The trial justice sentenced Defendant to forty years imprisonment. Defendant subsequently filed a pro se motion to reduce his sentence under the provisions of rule 35 of the superior court rules of criminal procedure, which allows a trial justice to grant leniency if he or she finds the sentence originally imposed was, for any reason, unduly severe. The trial justice denied the motion. The Supreme Court affirmed, holding that Defendant failed to demonstrate that the trial justice abused his discretion when he denied Appellant's motion to reduce his sentence. View "State v. Hak" on Justia Law

After a jury trial, Defendant William Tetreault was convicted of maliciously beating and sexually assaulting his girlfriend (Complainant) and sentenced to concurrent terms of thirty years' incarceration. Defendant appealed his convictions, alleging that the trial justice erred by (1) disallowing opinion testimony as to Complainant's character for truthfulness, and (2) allowing into evidence eleven of Defendant's prior convictions, which were used to impeach his credibility as a witness. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice carefully considered the proferred evidence in both instances and did not abuse his discretion in either of the contested evidentiary rulings. View "State v. Tetreault" on Justia Law

Defendant Brian Dennis was twice convicted of felony crimes involving sexual misconduct. After Defendant's second conviction, the Sex Offender Board of Review assessed Defendant's level of risk of re-offending that he posed to the community. The Board classified Defendant as a level three, high risk sexual offender. The superior court magistrate affirmed. The Supreme Court affirmed, holding (1) the superior court magistrate did not err by finding that the State established a prima facie case justifying the Board's decision to classify Defendant as a level three sex offender; (2) Defendant was afforded a meaningful hearing when the superior court reviewed Defendant's classification level, and therefore, Defendant's right to procedural due process was not violated; (3) because the Board properly relied upon a range of materials to formulate its decision to deviate from the risk level indicated by the objective tests, the superior court magistrate did not err in finding that competent evidence existed to support the Board's assessment and upholding the classification. View "State v. Dennis" on Justia Law

After a jury trial, Defendant Emmanuel Karngar was found guilty of breaking and entering. Defendant appealed, arguing that his motion for a new trial should have been granted based on the lack of credibility of the complaining witness, the lack of evidence in light of the charge, and the overall insufficiency of the evidence. The Supreme Court affirmed the superior court, holding (1) Defendant's motion for a new trial failed to challenge the sufficiency of the evidence, and therefore the Court declined to decide that claim; and (2) the trial justice did not abuse his discretion in finding that reasonable minds could disagree about the witnesses' credibility and that the verdict was not against the weight of the evidence. View "State v. Karngar" on Justia Law

Anthony DeCiantis was convicted of murder in the first degree and received a life sentence. DeCiantis filed a third application for postconviction relief, the subject of this appeal, alleging, inter alia, prosecutorial misconduct and that the prosecution intentionally withheld an uncharged act admitted to by one of its witnesses. The superior court dismissed the application, and DeCiantis appealed. The Supreme Court affirmed, holding (1) the hearing justice did not err in his determination that no prosecutorial misconduct occurred, and (2) although the witness's uncharged crimes should have been disclosed to DeCiantis, DeCiantis did not satisfy his burden of showing that the nondisclosed evidence was material. View "DeCiantis v. State" on Justia Law

Defendant Mark Sampson was convicted for second degree child abuse in superior court pursuant to R.I. Gen. Laws 11-9-5.3, otherwise entitled Brendan's Law. Defendant appealed, making several arguments, including that the trial justice erred because (1) Brendan's Law was unconstitutionally vague; and (2) Defendant did not knowingly, intelligently, and voluntarily waive his right to counsel. The Supreme Court reversed, holding that the trial justice erred in forcing Defendant to choose to defend himself pro se or proceed to trial with an attorney who refused to implement Defendant's personal right to waive a jury, and thus Defendant never knowingly, intelligently, and voluntarily waived his right to counsel. The Court did not address the remainder of Defendant's arguments except to impart a specific instruction to the superior court with respect to the proceedings on remand, holding it was error for the trial justice to construe Brendan's Law to, in effect, delete the word "serious" in the statute. Accordingly, an adjudication that a defendant is guilty of second degree child abuse requires a determination as to whether the defendant inflicted a serious physical injury. Remanded. View "State v. Sampson" on Justia Law

After a jury trial, defendant Tracey Barros was convicted of conspiracy to commit murder, first-degree murder, discharging a firearm while committing a crime of violence, and unlawfully carrying a firearm without a license. On appeal, Defendant contended that the trial justice erred when he (1) denied Defendant's motion to suppress his confession, and (2) precluded cross-examination of a prosecution witness with respect to purported third-party-perpetrator evidence. The Supreme Court affirmed, holding (1) the trial justice did not err in denying Defendant's motion to suppress as a review of the record revealed that Defendant's statements were voluntary and the timing of Defendant's presentment was not operative in inducing him to make his confession; and (2) the trial justice did not err in granting the prosecution's motion in limine to preclude the admission of third-party-perpetrator evidence because Defendant did not offer evidence reasonably specific to establish (a) that the individuals referred to had an opportunity to commit the crime or (b) a proximate connection between the individuals and the victim. View "State v. Barros" on Justia Law