Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of second-degree child molestation following a jury trial, holding that there was no abuse of discretion on the part of the trial justice with respect to the admission of testimony from a physician and from Defendant's brother-in-law.Specifically, the Supreme Court held (1) the trial justice did not commit reversible error by allowing the testimony of a physician testifying as an expert witness with respect to four statements with which Defendant took issue; and (2) Defendant's contentions with respect to the cross-examination of his brother-in-law were waived. View "State v. Benitez" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of assault with a dangerous weapon and other firearm-related counts stemming from a shooting incident, holding that the trial justice did not err in denying Defendant's motion for a new trial.On appeal, Defendant argued that the trial justice erred by overlooking or ignoring material evidence that Defendant asserted provided another person with an equal opportunity to commit the charged offenses. The Supreme Court affirmed, holding (1) there was no error in the trial justice's application of the required three-step analysis; and (2) the trial justice did not overlook or misconceive material evidence in denying Defendant's motion for a new trial. View "State v. Rego" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of simple domestic assault or battery and domestic refusal to relinquish or to damage or to obstruct telephone, holding that there was no error in the trial justice's rulings in this case.On appeal, Defendant argued that the trial court committed reversible error when it impermissibly prevented and restricted his cross-examination of the complaining witness, in violation of the Sixth Amendment. The Supreme Court affirmed, holding that, given the wide discretion afforded to trial justices in limiting the extent of cross-examination, the trial justice did not err in its challenged rulings. View "State v. Garcia" on Justia Law

The Supreme Court affirmed the decision and judgment of the superior court denying Defendant's motion to correct an illegal sentence pursuant to Rule 35(a) of the Superior Court Rules of Criminal Procedure, holding that Defendant waived his argument on appeal.Defendant pled guilty to several counts related to a gang-related shooting, including first-degree murder, weapons charges, assault, and conspiracy. The trial justice sentenced Defendant to a mandatory term of life imprisonment for first-degree murder, fifty years' imprisonment for offenses ancillary to the shooting, and an additional consecutive ten-year term of imprisonment pursuant to the criminal street gang enhancement statute. Defendant later filed a motion to correct his sentence, asserting that the State had failed to timely notify him of its intention to pursue the criminal street gang sentencing enhancement. The trial justice denied the motion, concluding that Defendant had expressly waived his right to timely notice as part of his agreement with the State. The Supreme Court affirmed, holding that Defendant's waiver of notice under the criminal street gang enhancement statute was valid, and therefore, Defendant's motion to correct sentence was properly denied. View "State v. Briggs" on Justia Law

The Supreme Court affirmed Defendant's judgment of conviction and the denial of his motion for a new trial, holding that the trial justice did not err or abuse her discretion in denying Defendant's motion for a new trial.Following a jury trial, Defendant was convicted of four counts of first-degree child molestation and sexual assault. On appeal, Defendant argued that the trial justice erred by denying his motion for a new trial because the trial justice overlooked material evidence. The Supreme Court affirmed, holding that the trial justice articulated adequate grounds for denying Defendant's motion for a new trial and that the trial justice did not overlook material evidence. View "State v. Vazquez" on Justia Law

The Supreme Court affirmed a superior court judgment of conviction for second-degree sexual assault following a 1993 jury trial and a 2019 superior court judgment adjudicating Defendant a probation violator for his failure to appear for execution of his sentence for that 1993 conviction, holding that there was no error.In 1993, a jury found Defendant guilty of one count of second-degree sexual assault and sentenced him to ten years' imprisonment. Defendant failed to appear for execution of his sentence, and a superior court clerk entered a judgment of conviction and commitment. In 2017, Defendant was arrested and extradited to Rhode Island. In 2018, a second trial justice ordered Defendant to begin serving the unsuspended portion of his original sentence. Thereafter, the State filed a notice of probation violation alleging that Defendant failed to comply with a probation condition when he failed to appear for execution of his sentence. The trial justice declared Defendant a violator of the terms of his probation and sentenced him to an additional three years' incarceration. The Supreme Court affirmed, holding that the trial justice did not err in adjudging Defendant a probation violator for his failure to appear for execution of his sentence. View "State v. Bienaime" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of voluntary manslaughter, holding that there was no error in the proceedings below.On appeal, Defendant argued that the jury erroneously rejected his claim of self-defense when it returned a verdict of guilty of voluntary manslaughter. The Supreme Court affirmed, holding (1) in its role as fact-finder, the jury was free to reject Defendant's claim of self-defense; and (2) because this issue was never before the trial justice in the context of a motion for a new trial or a motion for judgment of acquittal, the trial justice did not weigh the evidence or pass upon the credibility of witnesses. View "State v. Stevens" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree child molestation sexual assault, holding that the trial justice did not err in denying Defendant's motion for a mistrial.On appeal, Defendant argued that the State posed a question to the complaining witness that was highly prejudicial and violated a pretrial order, and therefore, his motion for a mistrial was improperly denied. The Supreme Court affirmed, holding (1) there was nothing in the record to suggest that the jurors could have been so inflamed by the brief exchange such that they would be unable to examine the evidence in a calm and dispassionate manner; and (2) therefore, the superior court did not err in denying Defendant's motion for a mistrial. View "State v. Barboza" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree murder, assault with intent to commit a felony, and two counts of discharging a firearm while committing a crime of violence, holding that there was no error in the proceedings below.Specifically, the Supreme Court held that the trial court did not err in (1) denying Defendant's motion to suppress evidence obtained from Defendant's cell phone, which police seized following his warrantless arrest; (2) denying Defendant's motion to discharge the jury impaneled on October 12, 2017 in violation of the Sixth Amendment; and (3) denying Defendant's motion to pass the case and for a mistrial. View "State v. Gonzalez" on Justia Law

The Supreme Court vacated the judgment of the superior court finding Defendant guilty of possession of child pornography and sentencing him to a suspended term of incarceration, with probation, and ordering him to meet special conditions of probation and to register as a sex offender, holding that there was no substantial basis for determining that probable cause existed in this case.On appeal, Defendant argued, among other things, that the superior court erred in denying his motion to suppress evidence that was seized from his home on the grounds that there was no probable cause to support the issuance of a search warrant. The Supreme Court agreed and vacated Defendant's convictions, holding that there was no substantial basis for determining that probable cause existed in this case based upon the language of the affidavit. View "State v. Resiner" on Justia Law