Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court vacated the judgment of the superior court dismissing Appellant’s application for postconviction relief, holding that Appellant was not afforded counsel in accordance with Shatney v. State, 755 A.2d 130 (R.I. 2000).After Appellant was convicted, he filed an application for postconviction relief. A justice of the superior court appointed counsel to represent him. After examining Appellant’s claims, counsel moved to withdraw from the case. The hearing justice granted the motion, concluding that Appellant’s claims lacked merit. The hearing justice then denied Appellant’s application for postconviction relief. The Supreme Court vacated the judgment below, holding that, after counsel’s motion to withdraw was granted, Appellant was not provided with a meaningful opportunity to reply to the hearing justice’s proposed dismissal of his application for postconviction relief. View "Hernandez v. State" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of second-degree sexual assault, holding that even if Defendant’s issue on appeal had been properly preserved for appellate review, no reversible error occurred.On appeal, Defendant argued that the trial judge erred by allowing testimony by the responding officer in which he commented on the complaining witness’s credibility. Specifically, Defendant argued that this testimony was impermissible bolstering or vouching of the witness’s credibility. The Supreme Court affirmed, holding (1) Defendant failed properly to preserve his objection for appeal because he did not provide a specific basis for the objection at trial; and (2) the admission of the testimony did not constitute prejudicial error. View "State v. Dalton" on Justia Law

The Supreme Court affirmed the order of the superior court denying Defendant’s motion to reduce a sentence, holding that the trial justice was within his discretion to give and confirm the punishment for Defendant.Defendant was convicted of one count of first-degree child molestation sexual assault. Defendant was originally sentenced to a forty-year term to serve but, after the case was remanded, he was sentenced to life imprisonment. Defendant filed a motion to reduce the sentence, arguing that the life sentence imposed after the second trial was unconstitutional. The trial justice denied the motion. Defendant appealed, arguing that the trial justice abused his discretion by imposing a sentence significantly longer than the sentence imposed after his first conviction. The Supreme Court affirmed, holding that the trial justice properly decided to impose the maximum sentence permitted under the statute in this case and that Defendant failed to demonstrate that the sentence was grossly disparate from other sentences generally imposed for similar offenses. View "State v. Oliveira" on Justia Law

The Supreme Court quashed the order of the superior court finding Defendant guilty of one count of second-degree murder and one count of discharging a firearm while committing a crime of violence, holding that the trial justice erred in granting Defendant’s motion for a new trial by exceeding the scope of this Court’s remand order.After Defendant was convicted, he timely appealed to the Supreme Court but ultimately moved to remand the matter to the superior court for a new trial in light of newly discovered evidence. The Supreme Court granted the motion, and on remand, the trial justice granted Defendant’s motion for a new trial on the ground set forth in his supplemental memoranda - that the trial justice’s jury instructions regarding involuntary manslaughter were improper under State v. Diaz, 46 A.3d 849 (R.I. 2012). The Supreme Court quashed the superior court’s order, holding that the trial justice did not have the authority to consider Defendant’s new-trial arguments based on Diaz, as the arguments fell outside the four corners of the original remand order. View "State v. Arciliares" on Justia Law

The Supreme Court affirmed the order of the family court requiring Defendant to register as a sex offender and denying his motion to waive sex-offender registration and notification pursuant to R.I. Gen. Laws 11-37.1-4(j), holding that there was no error in the proceedings below.On appeal, Defendant argued that the words of section 11-37.1-4(j) that “the conduct of the parties is criminal only because of the age of the victim” plainly applied to his case and that the trial justice should have exercised her discretion under section 11-37.1-4(j) to waive sexual-offender registration. The Supreme Court disagreed, holding (1) the trial justice appropriately determined that the coercion in this case made the conduct at issue criminal, apart from the ages of the victims; and (2) the trial justice appropriately applied the plain language of the statute in determining that she had no discretion in the present case. View "In re B.H." on Justia Law

The Supreme Court affirmed Defendant’s conviction of three counts of second-degree child molestation sexual assault, holding that the trial justice properly admitted testimony regarding previous restraining orders against Defendant and did not err in denying Defendant’s motion for a new trial.Specifically, the Court held (1) the “raise-or-waive” rule precluded Defendant from raising the issue of the admission of the challenged testimony, but even if Defendant had properly preserved the issue on appeal, defense counsel opened the door to the State’s inquiry on the topic during his cross-examination of the witness; and (2) the trial justice did not abuse his discretion in denying Defendant’s motion for a new trial. View "State v. Romero" on Justia Law

The Supreme Court vacated the judgment of the superior court in favor of Rhode Island Resource Recovery Corporation (Resource Recovery) in the amount of $5,733,648.18, inclusive of interest, on Resource Recovery’s claims of professional malpractice and breach of contract, holding that the trial justice erred in failing to grant Restivo Monacelli LLP’s (Restivo) motion for judgment as a matter of law.Although Restivo raised numerous contentions as to alleged error by the trial justice, the Supreme Judicial Court on appeal focused its inquiry only on Restivo’s contention that the trial justice erred in denying its motion for judgment as a matter of law because expert testimony with respect to proximate cause was required but was not presented by Resource Recovery. The Supreme Judicial Court agreed with Restivo, holding that expert testimony on the issue of proximate cause was required in this case, and Resource Recovery did not provide the required expert testimony as to proximate cause. View "Rhode Island Resource Recovery Corp. v. Restivo Monacelli LLP" on Justia Law

The Supreme Court affirmed Defendant’s conviction for carrying a firearm without license and other firearm-related offenses.After Defendant filed his appeal, he filed in the Supreme Court a motion to hold the appeal in abeyance and remanded the matter to the superior court to allow him to seek a new trial based on alleged violations of Brady v. Maryland, 373 U.S. 83 (1963). The Court denied Defendant’s motion to hold the appeal in abeyance but granted the remand motion. A hearing on the alleged Brady violation was held before the same justice of the superior court who presided over Defendant’s trial. The trial justice denied both the Brady-related motion for a new trial and Defendant’s motion to recuse the trial justice. The Supreme Court affirmed, holding that the trial justice did not commit prejudicial error by (1) denying Defendant’s motion to suppress two witnesses’ show-up identifications; (2) admitting the recording of an anonymous 911 call at trial; (3) determining that the state did not commit a Brady violation; and (4) denying Defendant’s motion to recuse the trial justice. View "State v. Washington" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant for the second-degree murder of his girlfriend’s six-year-old son.On appeal, Defendant claimed that he was entitled to a new trial because the trial justice erred in instructing the jury and in admitting certain testimony at trial. The Supreme Court disagreed, holding (1) the trial justice did not err with respect to her instruction on second-degree felony murder; (2) the trial justice did not err with respect to her instruction on causation; and (3) the trial justice did not err in allowing the challenged testimony once Defendant opened the door to its relevancy. View "State v. Pati" on Justia Law

The Supreme Court affirmed the decree of the family court declaring that Mother neglected and abused her two children, Madlyn and Luke.Specifically, the Court held (1) there was sufficient evidence to support an inference that Mother had abused and neglected Luke; (2) the trial justice did not err in finding that Mother was Luke’s primary caregiver and that it was reasonable to infer that Mother either perpetrated physical abuse upon Luke or allowed the same to occur; (3) Mother’s argument that certain statements made by a physician were inadmissible hearsay was waived; and (4) the trial justice did not abuse his discretion in allowing Father to remain in the courtroom, notwithstanding Mother’s motion to sequester. View "In re Madlyn B." on Justia Law