Justia Rhode Island Supreme Court Opinion Summaries

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

Defendant Paul Grieder assaulted plaintiff Michael Trainor and pled nolo contendere to one count of simple assault and battery and one count of felony assault. Plaintiff sued defendant in superior court, seeking damages for his injuries. Judgment was entered in plaintiff's favor in the amount of $1.5 million, but defendant refused to render payment in full to plaintiff. In the current case, plaintiff filed suit against defendant in superior court, attempting to recover his due. Defendant filed a motion to dismiss for lack of jurisdiction due to the fact that there had been no return of the execution on the judgment. The hearing justice ruled that since defendant had not raised the jurisdictional issue before the court on prior occasions, he had waived it, and therefore, the defendant's motion was dismissed. On appeal, the Supreme Court affirmed, holding (1) the superior court had subject matter jurisdiction, and (2) defendant waived the requirement that there be a return of the execution on the judgment. View "Trainor v. Grieder" on Justia Law

After a violation report was filed against defendant Ramondo Howard alleging defendant had violated the terms and conditions of his probation, defendant filed a pro se motion indicating that he wished to release his attorney and wanted new counsel to be appointed, confirming on the record he had filed a complaint against his attorney with the court's disciplinary board. The hearing justice excused defendant's attorney. Defendant then filed motions to recuse and change venues, both of which the hearing justice denied. At the violation hearing, the hearing justice found defendant to be a violator of the terms and conditions of his probation. Before the hearing began, however, the hearing justice expressed his belief that defendant needed to be "warehoused" and was "beyond rehabilitation." Defendant appealed, arguing the hearing justice erred by failing to recuse himself from the case because the justice lacked the objectivity and impartiality to fairly hear and render judgment. The Supreme Court reversed, finding that because the hearing justice chose to express his opinions prior to the commencement of the violation hearing, the justice displayed a clear inability to render fair judgment and erred by declining to recuse under the circumstances. Remanded. View "State v. Howard" on Justia Law

Defendants Norman Cipriano, Jr. and Jamie Bryant were convicted of receiving stolen goods with a value in excess of $500 and for conspiring to commit larceny. On appeal, defendants argued that the trial justice erred in (1) denying their motions for acquittal because the evidence was legally insufficient to establish the elements of each crime, and (2) refusing to instruct the jury about impermissible pyramiding of inferences and in the judge's charge concerning proof beyond a reasonable doubt. Cipriano additionally argued that the trial justice erred in (1) refusing to pass the case after a witness testified to seeing Cipriano on a prison bus, leaving the jury to infer that Cipriano had a general criminal disposition; and (2) in denying Cipriano's motion for a new trial. The Supreme Court affirmed, holding (1) the evidence was sufficient for denying the motion for judgment of acquittal; (2) the requested jury instructions were unnecessary and the trial justice adequately instructed the jury concerning reasonable doubt; (3) the trial justice did not abuse his discretion by refusing to pass the case or err by not giving a curative instruction; and (4) the trial justice did not err in declining to grant a new trial. View "State v. Cipriano" on Justia Law

Defendant Michael English pled nolo contendere to four counts of first-degree child molestation, one count of second-degree molestation, and one count of contributing to the delinquency of a minor, arising out of his relationship with victim, M.B. More than a decade later, the state filed a probation-violation notice, alleging that defendant had violated the conditions of his probation by failing to adhere to the terms of the no-contact order after M.B. complained that defendant had come into contact with her. The hearing justice concluded that defendant violated the terms of his probation, and the superior court adjudicated defendant a violator of probation. Defendant appealed, arguing that his contact with M.B. was merely coincidental and therefore insufficient to constitute a violation of probation. The Supreme Court affirmed, holding that the hearing justice's determination that the state's evidence supported an adjudication of probation violation was neither arbitrary nor capricious. View "State v. English" on Justia Law

A police surveillance operation at a street intersection led to the conviction of defendant, Geornando Vargas, for one count of delivery of a controlled substance. On appeal, defendant argued (1) that the trial justice erred by denying his motion for judgment of acquittal because the evidence presented by the state amounted to an improper pyramiding of inferences and therefore was legally insufficient to support defendant's conviction, and (2) the trial justice erred by denying his motion for a new trial because the justice misconceived the testimony of one of the state's witnesses. The Supreme Court affirmed, holding (1) that rather than deducing guilt from an ambiguous circumstantial fact, the state established a pattern of corroborating circumstances sufficient to justify a reasonable juror in finding defendant guilty beyond a reasonable doubt, and therefore affirmed the trial justice's denial of defendant's motion for acquittal; and (2) the trial justice did not misconceive the evidence when ruling on the defendant's motion for a new trial, and therefore, the trial justice did not err in denying the motion. View "State v. Vargas" on Justia Law