Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court vacated the judgment of the family court convicting Defendant of cruelty to or neglect of a child and sentencing her to a one-year suspended term of imprisonment, with probation, holding that a new trial was required.On appeal, Defendant argued that the trial justice erred by proceeding with a bench trial without obtaining a knowing, intelligent, and voluntary waiver of Defendant's right to a jury trial and erred in finding habitual neglect in this case. The Supreme Court vacated the judgment below, holding that because there was nothing in the record indicating that the trial justice was assured by Defendant that her waiver of a jury trial was made intelligently and with full knowledge of the consequences of her waiver, the case must be remanded for a new trial. View "State v. Michaud" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree murder, discharging a firearm during the commission of a crime of violence, and carrying a firearm without a license, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held that the trial court (1) did not abuse its discretion by denying Defendant's motion to suppress a witness's in-court identification and determining that the witness was a competent witness; (2) properly limited Defendant's cross-examination of two witnesses; and (3) articulated adequate grounds for denying Defendant's motion for a new trial and did not overlook or misconceive material evidence. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant on eight criminal counts related to a robbery and the resulting exchange of gunshots, holding that there was no error in the proceedings below.A jury found Defendant guilty of first-degree robbery, assault with a dangerous weapon, and other convictions. The trial justice ordered Defendant to serve a life sentence as to count one. The Supreme Court affirmed, holding (1) the trial justice did not commit reversible error in refusing to instruct the jury about the withdrawal exception to the initial aggressor rule as it related to the self-defense instruction; and (2) under the circumstances of this case, the trial justice did not abuse his discretion in denying Defendant's motion for a bill of particulars and motion to compel such. View "State v. Isom" on Justia Law

The Supreme Court affirmed the judgment of the superior court adjudicating Defendant a probation violator, affirmed the order denying Defendant's motions to dismiss and to reconsider, and affirmed the hearing justice's denial of Defendant's motion to recuse, holding that Defendant's arguments on appeal failed.Specifically, the Supreme Court held (1) given the nature and extend of Defendant's conduct in contributing to the delay in this case, the hearing justice did not err in denying Defendant's motion to dismiss and his motion to reconsider the finding of his probation violation based on the delay between his arrest and the violation hearing; (2) there was sufficient evidence to find that Defendant violated his probation; and (3) the hearing justice acted well within his discretion in sentencing Defendant to six years of his remaining suspended sentence. View "State v. Molina" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of second-degree murder, receiving stolen goods, conspiracy, operating a vehicle on a suspended license, and carrying a knife greater than three inches in length, holding that there was no error.Specifically, the Supreme Court held (1) the trial justice did not err in denying Defendant's motion to suppress the fruits of his third interrogation; (2) the trial justice did not err by declining to redact certain prejudicial statements Defendant made while he was alone in the interrogation room; (3) Defendant's argument that his detention was extensive and that he was denied prescription medication during detention was waived; and (4) Defendant's argument that the trial justice abused his discretion by failing to suppress a witness's out-of-court identification was also waived. View "State v. Baribault" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of first-degree sexual assault and three counts of second-degree child molestation after a jury trial, holding that there was no error in the proceedings below.On appeal, Defendant argued that the trial justice clearly erred in denying his motion for a new trial because the justice overlooked and misconstrued material evidence and the weight of the evidence did not support the verdict. The Supreme Court disagreed and affirmed, holding that there was no reversible error in the trial justice's analysis of the motion for a new trial or in his decision denying the motion. View "State v. Acosta" on Justia Law

The Supreme Court affirmed the judgment of conviction and commitment entered in the superior court reflecting the fact that Defendant was found guilty of second-degree murder, holding that the trial justice did not err when she denied Defendant's motion to suppress.Before trial, Defendant filed a motion to videos located on a digital camera, arguing that the detectives who seized the camera improperly expended the scope of the judicially-approved warrant. The trial justice denied the motion. After a jury trial, Defendant was found guilty of second-degree murder and sentenced to life imprisonment. The Supreme Court affirmed, holding that the trial justice did not clearly err in denying the motion to suppress because, in seizing the camera, the police did not exceed the scope of the warrant. View "State v. Depina" on Justia Law

The Supreme Court affirmed Defendant's conviction for six counts of first-degree child molestation sexual assault, three counts of second-degree child molestation sexual assault, and second-degree child abuse, holding that there was no error in the proceedings below.On appeal, Defendant argued among other things, that the trial justice erred in admitting evidence of past bad acts without articulating the special relevance of the evidence in the limiting instructions. The Supreme Court disagreed, holding (1) the trial justice did not overlook or misconceive material evidence in denying Defendant's motion for a new trial; and (2) the trial justice did not err in admitting evidence under Rule 404(b) of the Rhode Island Rules of Evidence because Defendant's objection to the instructions he sought to argue was waived. View "State v. Phillips" on Justia Law

The Supreme Court vacated Defendant's conviction for assault and battery with a dangerous weapon, leaving the scene of an accident resulting in physical injury, reckless driving resulting in physical injury, and violating a no-contact order, holding that the trial justice erred in instructing the jury, resulting in reversible error.Defendant's conviction arose from a bar fight and its aftermath, when Defendant drove his vehicle into two women and then fled the scene. Three counts arose from violations of a no-contact order. On appeal, Defendant argued, among other things, that the trial justice committed reversible error when he instructed the jury that it was entitled to consider whether he was intoxicated at the time of the incident. The Supreme Court agreed and remanded the case for a new trial, holding (1) the trial justice erred when he instructed the jury that it could consider Defendant's intoxication, and the error required reversal of Defendant's convictions; and (2) the trial justice erred in ruling that two separate counts of violating a no-contact order did not merge. View "State v. Narcovich" on Justia Law

The Supreme Court vacated the judgment of the superior court convicting Defendant of possession of child pornography and sentencing him to a term of imprisonment of five years, with two years suspended, with probation, holding that the trial justice erred by denying Defendant an opportunity to address the jury with an opening statement.Defendant chose to proceed pro se at trial. Immediately after the State delivered its opening statement, Defendant also sought to offer an opening statement. Following a colloquy, the trial justice refused to allow Defendant to make an opening statement. The Supreme Court vacated the judgment below, holding that the trial justice erred when he did not make a proper inquiry of Defendant before precluding him from making an opening statement to the jury. View "State v. Smith" on Justia Law