Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the superior court declaring Defendant to be a probation violator and sentencing Defendant to the nine years remaining on his suspended sentence, holding that there was no error or abuse of discretion.On appeal, Defendant argued that the order to serve the nine years remaining on his suspended sentence was improperly based on the new charges alone, without proper attention being given to the original conviction for which he was on probation. The Supreme Court affirmed, holding that the hearing justice acted within her discretion by executing the full nine years of Defendant's original suspended sentence. View "State v. Segrain" on Justia Law

The Supreme Court affirmed the judgment of the superior court finding Defendant guilty of assault with a dangerous weapon - a shod foot - and driving while intoxicated, holding that the trial justice did not err when she instructed the jury about the concept of aiding and abetting and that Defendant's Frye hearing was not conducted in error.On appeal, Defendant argued that the trial justice erred in charging the jury that it could convict him as either a principal or as an aider and abetter and that the trial justice erred during the Frye hearing because she failed to put him on notice that he was exposed to criminal liability for aiding and abetting. The Supreme Court affirmed, holding (1) an instruction on aiding and abetting was justified by the evidence; and (2) the trial justice did not err in the manner in which she proceeded during the Frye hearing. View "State v. Haffner" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of two counts of felony assault, holding that the trial justice did not abuse his discretion by permitting the state to impeach Defendant with a prior felony assault conviction.Defendant's first jury trial ended in a mistrial after a hung jury. After a second criminal jury trial before a different trial justice, the jury found Defendant guilty of two counts of assault with a dangerous weapon. On appeal, Defendant argued that the second trial justice abused his discretion by deviating from the law of the case doctrine and allowing a prior felony assault conviction to be introduced for impeachment purposes. The Supreme Court affirmed, holding that, under the circumstances, the trial justice did not abuse his discretion by allowing the State to impeach Defendant's credibility with his prior felony assault conviction. View "State v. Jones" on Justia Law

The Supreme Court affirmed the order of the superior court denying Defendant's motion for a new trial, holding that the motion for a new trial was untimely filed.Defendant was found guilty of sex trafficking of a minor and conspiring to do so and three counts of first-degree sexual assault. The Supreme Court vacated the convictions for sex trafficking of a minor and conspiring to do so and otherwise affirmed. Defendant subsequently filed a second motion for a new trial, arguing that the vacatur of his convictions on counts four and six constituted newly available evidence, allowing him to file this motion. The trial justice denied the motion. The Supreme Court affirmed, holding that the motion for a new trial was filed outside of the ten-day time limit set forth in Rule 33, which cannot be waived. View "State v. Maxie" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of eighteen counts of financial fraud crimes and sentencing him to a total of seven years to serve in prison, with the balance of the eighteen concurrent sentences suspended with probation, holding that the trial justice did not err or abuse her discretion.Specifically, the Supreme Court held (1) the trial justice did not abuse her discretion in admitting evidence related to Defendant's character; (2) the trial justice did not err by permitted a Rhode Island State Police detective to provide expert opinion testimony as a lay witness; (3) the trial justice was not clearly wrong in allowing a waiver of the attorney-client privilege; (4) the trial justice did not err when she denied Defendant’s motion to suppress evidence he claimed was illegally obtained by state action; (5) the trial justice did not err by denying Defendant's motion for a new trial; and (6) Defendant waived his remaining allegations of error. View "State v. Doyle" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree robbery and assault with a dangerous weapon in a dwelling with intent to rob, holding that the trial justice did not abuse her discretion in excluding the complaining witness's prior criminal convictions and excluding photographs of bruises on Defendant's torso and supporting testimony from an investigator.Specifically, the Supreme Court held (1) the trial justice did not abuse her discretion in excluding evidence of the complaining witness's prior convictions for resisting arrest and domestic disorderly conduct; and (2) the trial justice did not abuse her discretion in excluding the photographs and supporting testimony because, without further evidence connecting the injuries depicted in the photographs to the altercation with the complaining witness that occurred nearly two weeks earlier, the evidence was inadmissible. View "State v. Lamontagne" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant on two counts of first-degree child molestation sexual assault, holding that the trial justice did not err in denying Defendant's motion to suppress statements made to the state police, denying Defendant's motion for a mistrial, and denying Defendant's motion to dismiss counts one and two of the indictment pursuant to Rule 29(b) of the Superior Court Rules of Criminal Procedure.Specifically, the Supreme Court held (1) Defendant's waiver of his Miranda rights was made knowingly, intelligently, and voluntarily, and therefore, the trial justice properly denied Defendant's motion to suppress; (2) the trial justice did not err when she denied Defendant's motion for a mistrial based on an alleged discovery violation by the State; and (3) the trial justice did not err when she credited the complaining witness's testimony in denying Defendant's Rule 29(b) motion to dismiss the first two counts of the indictment relating to first-degree child molestation sexual assault. View "State v. Alvarado" on Justia Law

The Supreme Court vacated the order of the superior court suppressing the DNA results of a buccal swab taken from Defendant pursuant to a valid search warrant while he was incarcerated, holding that the trial justice erred in suppressing the buccal swab evidence.Three years after the murder of Robert Bullard Defendant was apprehended and taken into custody. A criminal complaint was filed, and Defendant was held without bail at the Adult Correctional Institutions (ACI). Thereafter, a detective obtained search warrants to collect Defendant's DNA at the ACI using a buccal swab. When Defendant refused to comply with the search warrants law enforcement officers used force to obtain the buccal swab. Defendant filed a motion to suppress the DNA evidence, which the trial court granted. The Supreme Court vacated the trial court's order, holding that the use of force was objectively reasonable because the intrusion into Defendant's Fourth Amendment interests was minimal and was far outweighed by countervailing government interests. View "State v. Querido" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Appellant's application for postconviction relief, holding that Appellant's claims lacked merit.Appellant was convicted of first-degree murder, discharging a firearm during the commission of a crime of violence, and conspiracy. Appellant later filed a pro se application for postconviction relief, arguing that newly discovered evidence required a new trial, that the trial justice impermissibly amended the indictment, and that a consecutive life sentence for discharging a firearm during the commission of a crime of violence should not have been imposed. The hearing justice denied the application for postconviction relief. The Supreme Court affirmed, holding (1) the hearing justice correctly found that Appellant's evidence did not meet the test for newly discovered evidence; and (2) Appellant's remaining claims were barred by res judicata and also lacked merit. View "Graham v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the superior court adjudicating Defendant to be in criminal contempt, holding that the trial justice's two-year consecutive sentence was clearly beyond the six-month maximum.Defendant was convicted for first-degree robbery and assault with a dangerous weapon in a dwelling. At sentencing, the trial justice deviated from the sentencing benchmarks and sentenced Defendant to thirty-five years' incarceration. When Defendant acted out in the presence of the court, the trial justice found Defendant in contempt of court. The trial justice sentenced Defendant to an additional two years' incarceration for criminal contempt, to be served consecutively with his sentence to serve on the underlying charges. The Supreme Court affirmed in part and reversed in part, holding (1) the trial justice was clearly within her authority in adjudicating Defendant in criminal contempt; but (2) Defendant's sentence for contempt was unlawful. View "In re Joseph I. Lamontagne" on Justia Law