Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of manufacturing or cultivating marijuana. The Supreme Court affirmed the conviction, holding that the trial justice (1) did not err in denying Defendant's motion for a judgment of acquittal as to the charge of manufacturing and cultivating marijuana where the evidence was legally sufficient to support the conviction; (2) did not err in denying Defendant's motion for a judgment of acquittal as to aiding or abetting the manufacture and cultivation of marijuana because the evidence supported that offense; and (3) did not err when he instructed the jury that it could convict Defendant of manufacturing or cultivating marijuana as an aider or abettor. View "State v. Long" on Justia Law

After a jury trial, Defendant was convicted of robbery in the first degree, conspiracy to commit robbery, breaking and entering a dwelling without consent while the owner was on the premises, carrying a firearm without a license, and using a firearm during the commission of a crime of violence. Defendant appealed, arguing that the trial justice erred by admitting into evidence unredacted photographs not only that portrayed his tattoos, but his face as well. The Supreme Court affirmed, holding that the trial justice did not abuse his discretion in determining that the pictures showing Defendant's face were relevant or in admitting the photographs into evidence. View "State v. Delarosa" on Justia Law

Plaintiff was injured while he was working for Defendant. Plaintiff began receiving partial disability benefits. Several years later, Plaintiff was notified that his benefits would be terminated. Plaintiff filed a petition requesting continuation of his benefits and/or a finding that he was totally disabled. After a trial, the workers' compensation court (WCC) denied the petition. The appellate division of the WCC affirmed. The Supreme Court granted Plaintiff's petition for a writ of certiorari and affirmed, holding (1) Plaintiff was not entitled to partial incapacity benefits because, contrary to Plaintiff's position, his failure to regain his earning capacity did not constitute a "material hinderance" to his finding employment suitable to his limitations within the meaning of R.I. Gen. Laws 28-33-18.3(a)(1); and (2) section 28-33-18 does not violate the equal protection clause of the Rhode Island Constitution. View "Nichols v. R&D Constr. Co." on Justia Law

In 1989, Defendant hired a law firm and one of its attorneys (collectively, Plaintiffs) to represent Defendant in her father's probate proceedings. The retainer agreement provided that Defendant would pay Plaintiffs fifteen percent of any amounts she recovered in exchange for any settlement Plaintiffs negotiated on her behalf. Plaintiffs successfully negotiated the probate settlement under the terms of which Defendant was to receive on half the interest and principal payable under a promissory note (Victory note). In 2002, Defendant discharged Plaintiffs as her attorney. In 2005, Defendant settled her claim pertaining to the Victory note in a receivership proceeding. Defendant received more than $1 million as payment of her claim, none of which Plaintiffs received. Plaintiffs subsequently filed suit against Defendant, alleging that Defendant breached her contract with them by failing to pay fifteen percent of each payment received under the receivership settlement as required by the 1989 retainer agreement. The trial court granted summary judgment for Plaintiffs, reasoning that Plaintiffs earned fifteen percent of any amounts received by Defendant when they successfully negotiated the probate settlement in 1989. The Supreme Court affirmed, holding that at the time Defendant discharged Plaintiffs, Plaintiffs' right to receive their fee from amounts eventually recovered by Defendant had vested. View "Law Firm of Thomas A. Tarro, III v. Checrallah" on Justia Law

After a jury trial, Defendant was convicted of several firearm offenses, eluding a police officer, and resisting arrest. Defendant's convictions were affirmed on appeal. Defendant subsequently filed an application for postconviction relief, claiming that the jury was improperly instructed and that the trial justice erred when he permitted an alcohol, tobacco, firearms, and exposives agent to "offer to the jury an opinion on the truthfulness of a statement" Defendant made. The trial justice dismissed Defendant's application. On appeal, Defendant argued that the agent's testimony was prejudicial and not capable of being cured with a cautionary instruction and that the cautionary instruction was improper. The Supreme Court affirmed, holding that Defendant's claims were barred by res judicata because Defendant failed to raise his claims on direct appeal. View "Hall v. State" on Justia Law

After a jury trial, Defendant was convicted of several acts of child molestation and sexual assault. Defendant filed a motion for a new trial, which the trial justice denied. The Supreme Court affirmed the denial of Defendant's motion for a new trial, holding that the trial justice independently evaluated the evidence and assessed the credibility of the witnesses and did not overlook relevant and material evidence, thoroughly reviewed and summarized the testimony of the trial witnesses and issued a comprehensive decision setting forth his reasons for denying the motion for a new trial, and therefore correctly determined that credible evidence existed to support the jury's finding of guilt. View "State v. Paola" on Justia Law

In 2003, Defendant was charged with obtaining money under false pretenses. Defendant pled nolo contendere to the charge and agreed to pay restitution. Defendant's sentencing was deferred for a period of five years. In 2010, Defendant filed a motion to seal her records under R.I. Gen. Laws 12-19-19(c), arguing that under the plain language of the statute as amended in 2010, she was eligible to have her records sealed, and that if the court found that retroactivity was an issue, section 12-19-19(c) was entitled to retroactive application. The superior court denied the motion, finding that the statute was not intended to be applied retroactively. The Supreme Court affirmed, holding (1) the plaint language of section 12-19-19 as amended did not imply that the General Assembly intended for it to apply retroactively; and (2) declining to apply section 12-19-19(c) retroactively would not reach an absurd result. View "State v. Morrice" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree. The trial justice imposed a sentence of life imprisonment without the possibility of parole. Defendant appealed, contending that the trial justice committed reversible error in (1) admitting acts of prior misconduct he allegedly committed against the decedent, (2) denying his motion for a new trial, and (3) sentencing him. The Supreme Court affirmed, holding that the trial justice did not err in (1) admitting testimony relating to Defendant's acts of prior misconduct for the limited purpose of demonstrating Defendant's intent; (2) denying Defendant's motion for a new trial, as the evidence was sufficient to convicted him of first-degree murder; and (3) sentencing Defendant to life imprisonment without the possibility of parole, as any mitigating factors were far outweighed by the aggravating factors present in this case. View "State v. Martinez" on Justia Law

After a jury trial, Defendant was convicted of four counts of first-degree sexual assault. The trial justice sentenced Defendant to four concurrent sentences of twenty years incarceration, ten years to serve, ten years suspended with probation. Defendant subsequently filed a motion to reduce his sentence, which the trial justice denied. Because the appeal was not timely filed, Defendant sought review by the Supreme Court by means of a petition for a writ of certiorari. The Court granted the petition and affirmed the decision of the superior court, holding that Defendant did not establish that the trial justice abused his discretion when he denied the motion to reduce Defendant's sentence, as the sentence was neither beyond the power of the sentencing justice to impose, nor was it patently unjustified. View "State v. Lynch" on Justia Law

Defendant pleaded guilty to manslaughter in 1994 and received a sentence of thirty years in prison with twenty years suspended, along with twenty years probation. In 2011, the superior court adjudged Defendant to be in violation of his probation and executed seven years of his previously suspended sentence. Defendant appealed, contending that the evidence presented at the probation-violation hearing was insufficient to support the hearing justice's finding that Defendant violated the terms of his probation. The Supreme Court affirmed, concluding, as did the hearing justice, that the evidence adduced at the hearing was sufficient to support a finding that Defendant had violated the terms of his probation. View "State v. Lamoureux" on Justia Law