Justia Rhode Island Supreme Court Opinion Summaries

Defendant Raymond Staffier was charged with four counts of second-degree child molestation. The case was submitted to the jury, and a verdict of not guilty was returned on count one with a finding of guilt on the remaining three counts. Defendant filed a pro se appeal, arguing that the trial justice erred (1) by denying his motion for a new trial because the inconsistent verdicts fail to do substantial justice and that this inconsistency cannot logically be explained, and (2) by allowing one of the state's witnesses to testify in contravention of a sequestration order. The Supreme Court affirmed, holding that (1) because the trial justice considered the evidence and ultimately found that the verdict was strongly supported by the evidence, the justice's inquiry rightfully ended when she agreed with the jury's verdict; and (2) because any violation of the sequestration order was unintentional, the testimony did not undermine the purpose of the sequestration order, and any potential harm to the defendant was addressed by the trial justice, the trial justice did not abuse her discretion when she allowed the testimony. View "State v. Staffier" on Justia Law

Shianna Kelly was found guilty by jury of entering a dwelling with the intent to commit larceny. Kelly appealed on the ground that the trial justice erred in denying her motion for a new trial. The Supreme Court affirmed, holding (1) the trial justice performed the correct analysis in deciding defendant's motion for a new trial and was not clearly wrong in denying the motion; (2) the trial judge did not err in refusing to grant a new trial on the basis that the judge allowed testimony after a discovery violation; and (3) the issue of whether a surveillance DVD and photographs were properly admitted at trial was not properly preserved for appellate review. View "State v. Kelly" on Justia Law

Plaintiff Horton appealed from a superior court grant of summary judgment in favor of the police department defendants, dismissing the plaintiff's thirteen-count complaint which alleged, among other complaints, malicious prosecution, false arrest, false imprisonment, tortious denial of access to public records, violations of civil rights, and failure to destroy records after exoneration. The Supreme Court affirmed, holding (1) defendants possessed probable cause for each instance of prosecution, arrest, and imprisonment, making a grant of summary judgment appropriate; and (2) because Horton failed to provide analysis of the remaining questions in his appeal, those contentions were deemed waived for appellate review. View "Duane Horton v. Portsmouth Police Dep't, et al." on Justia Law

Defendant Memeh Kizekai appealed the conviction and sentence he received for "uttering and publishing" when he and co-Defendant Sonnah Sampson tried to cash a $7500 counterfeit check at a Pawtucket bank. Defendant argued that he should have received a new trial because the evidence presented against him was not credible or sufficient to support his conviction. Defendant and the State agreed that the case turned on whose testimony was more credible: Sampson's or Defendant's. The trial court acknowledged its role as "the 13th juror," and held that its determination was based on "whether or not the evidence placed before the court was sufficient to substantiate and sustain the verdict that the jury achieved." The Supreme Court concluded that the trial court "did not shirk his super juror duties." The Court affirmed the lower court's decision.

Defendant Jose Torres appealed the denial of his motion for post conviction relief. On appeal to the Supreme Court, Defendant argued that the grand jury indictment wrongly charged him with murder. Although he ultimately pled to a lesser charge of manslaughter, Defendant contended that his conviction should be vacated because of an "inherently flawed indictment"--a defect not waived by his plea agreement. "[B]y voluntarily pleading guilty to a charge that was amended with his consent, [Defendant] waived any argument that the State could not have proven him guilty of murder." The Court affirmed the lower court's decision.

Defendant Gerald Lynch appealed his conviction and sentence on four counts of first-degree sexual assault. At trial after the close of evidence, the state dismissed two counts of Defendantâs indictment, and Defendant moved for an acquittal on the remaining counts. The trial judge waited for the jury to return its verdict before ruling on Defendantâs motion. The jury found Defendant guilty on four counts of sexual assault. The judge then denied Defendantâs motion. On appeal, defendant alleged that, among other things, the trial judge erred in denying his motion for acquittal because the state failed to prove its case against him. The Supreme Court found that the evidence presented at trial was sufficient to allow the jury to reach its conclusions and verdict. Finding no error, the Court affirmed the lower courtâs decision.