Justia Rhode Island Supreme Court Opinion SummariesArticles Posted in Juvenile Law
In re Joseph C.
The Supreme Court affirmed the judgment of the Family Court finding Respondent, a juvenile, delinquent for committing first-degree robbery and conspiracy to commit robbery.The only pertinent issue Respondent raised on appeal was whether the State met its burden of establishing the corpus delicti of the crimes of robbery and conspiracy to commit robbery such that the trial justice properly admitted Respondent’s confession into evidence. The Supreme Court concluded that the State did establish the corpus delicti of both first-degree robbery and conspiracy to commit robbery, and therefore, the trial justice did not err in admitting Respondent’s confession. View "In re Joseph C." on Justia Law
In the Matter of B.H.
In 2012, the Cranston Police Department filed delinquency petitions alleging that, when B.H. was 13 years old, he committed two offenses that, if committed by an adult, would constitute the offense of first-degree child molestation and one offense that, if committed by an adult, would constitute the offense of second-degree child molestation. The victims were 11-year-old boys.The Family Court found the B.H. delinquent for the violations under G.L. 1956 11-37-8.1 and 11-37-8.2. The Rhode Island Supreme Court remanded, finding that the evidence at the delinquency proceeding was insufficient to establish sexual penetration—an element of both of the charges of first-degree child molestation of which the respondent was adjudged to be delinquent. The court directed the Family Court to enter adjudications of delinquency on the lesser-included offense of second-degree child molestation sexual assault (second-degree child molestation). View "In the Matter of B.H." on Justia Law
In re Kyle A.
After an adjudication, Respondent was found delinquent for engaging in second-degree child molestation sexual assault. At the conclusion of a sentencing hearing, the family court ordered that Respondent register as a sex offender. Respondent appealed, arguing that legally sufficient evidence did not exist to support the finding that he was delinquent because his actions were motivated by sexual arousal or gratification. The Supreme Court affirmed the adjudication of the family court, holding that there was sufficient evidence to support the trial justice’s finding that Respondent touched the complainant for the purposes of sexual gratification. View "In re Kyle A." on Justia Law
In re J.S.
After J.S., a juvenile, injured an individual with a knife, the state police filed two petitions against J.S., including a petition alleging that J.S. was delinquent due to having committed an offense that, if committed by an adult, would constitute an assault with a dangerous weapon. The family court found J.S. delinquent for committing an assault with a dangerous weapon and placed him on probation. The Supreme Court affirmed, holding that there was sufficient legally competent evidence to support (1) the trial justice’s finding that the State presented sufficient evidence to disprove J.S.’s defense of self-defense beyond a reasonable doubt, and (2) the trial justice’s adjudication of Respondent as delinquent for having committed an assault with a dangerous weapon. View "In re J.S." on Justia Law
In re Frances G.
Twelve-year old Frances G. told a law enforcement officer that she threw a rock or brick against the windshield of a vehicle and carved something into the side of the vehicle. After a trial before a justice of the family court, Frances was adjudicated to be wayward. The Supreme Court affirmed, holding (1) the trial justice was not clearly wrong when she allowed the vehicle's owner to testify about what her daughter told her she saw Frances do to the car because the statement qualified as an "excited utterance" under R.I. R. Evid. 803(2); and (2) Frances knowingly and voluntarily waived her Miranda rights before speaking to the law enforcement officer, and therefore, the trial justice did not err in admitting the statement into evidence. View "In re Frances G." on Justia Law