Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the superior court convicting Defendant of five counts related to conduct stemming from a drive-by shooting, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) there was no need to reach the merits of Defendant's belatedly raised double jeopardy contention; (2) the trial justice did not err in denying Defendant's motion to suppress an eyewitness identification; (3) the trial justice did not err by summarily denying Defendant's motion to recuse; (4) Defendant was not denied his constitutional right to self-representation; and (5) Defendant's remaining arguments were not properly preserved for appellate review. View "State v. Segrain" on Justia Law

The Supreme Court affirmed the order of the district court committing Respondent to a residential living facility for adults with developmental disabilities, holding that there was no error or abuse of discretion.The Rhode Island Department of Behavioral Healthcare, Developmental Disabilities and Hospitals filed a petition for civil court certification to retain Respondent, a person with developmental disabilities, in a residential facility. The hearing justice found that Respondent was developmentally disabled and ordered that he reside at a group home. The Supreme Court affirmed, holding (1) Respondent's appeal was timely; and (2) Respondent waived his argument that the district court erred in allowing the admission of testimony regarding Respondent's juvenile conviction, his requirement to register as a sex offender, and other uncharged bad acts committed by Respondent. View "In re J.T." on Justia Law

The Supreme Court affirmed the superior court's entry of a judgment of conviction and commitment reflecting the fact that a jury found Defendant guilty of one count of first-degree sexual assault, holding that the trial justice did not abuse its discretion.Specifically, the Supreme Court held (1) the trial justice did not abuse its discretion in allowing an expert witness to testify after the State's late disclosure and fashioning a remedy in reaction to the late disclosure; (2) the trial justice did not abuse its discretion when he admitted the expert testimony because the testimony did not invade the province of the jury; and (3) Defendant's remaining argument was waived. View "State v. Sheridan" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree murder after a jury trial, holding that the trial justice did not err in denying Defendant's motion for a new trial.On appeal, Defendant arguing that the evidence failed to establish beyond a reasonable doubt that the victim's murder was premeditated and that the State failed to meet its burden of disproving voluntary manslaughter. The Supreme Court disagreed, holding that the trial justice did not overlook or misconceive any material evidence and did not err in denying Defendant's motion for a new trial. View "State v. Avila" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of driving under the influence, holding that Defendant was not entitled to relief as to her allegations of error.On appeal, Defendant argued that the trial justice erred in limiting her cross-examination of the arresting police officer, that the trial justice erroneously denied her motion for a new trial, and that there were pro of law regarding her motion for a new trial. The Supreme Court affirmed, holding (1) the trial justice's limitation of the cross-examination did not constitute an abuse of discretion; (2) there was no error in the trial justice's denial of Defendant's motion for a new trial based on the weight of the evidence; and (3) Defendant's remaining alleged errors of law were waived. View "State v. Ricker" on Justia Law

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