Articles Posted in Rhode Island Supreme Court

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The Supreme Court vacated the judgment of conviction after a jury found Defendant guilty of first degree sexual assault and murder, holding that Defendant was entitled to a new trial because the trial court violated the Confrontation Clause. In this cold case, Defendant was charged with the crimes for which he was convicted twenty-five years after the victim was murdered. On appeal, Defendant argued, among other things, that the trial justice erred by allowing statements of deceased declarants to be admitted into evidence, in violation of the Confrontation Clause. The Supreme Court agreed and vacated Defendant’s convictions, holding (1) the Confrontation Clause was violated when the State implicitly conveyed to the jury the content of statements made by deceased witnesses, both through a detective’s testimony and the closing argument of the prosecutor; and (2) these violations were not harmless beyond a reasonable doubt. The Court remanded the case to the superior court for a new trial. View "State v. Roscoe" on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of three counts of assault with a dangerous weapon, three counts of discharging a firearm while committing a crime of violence, and one count of carrying a pistol without a license, holding that there was no error or abuse of discretion in the proceedings below. On appeal, Defendant asked the Supreme Court to grant him a new trial on three grounds. The Supreme Court denied relief and affirmed the convictions, holding (1) Defendant waived his argument that the State untimely disclosed the identity of two witnesses who were placed in witness protection; (2) the trial justice did not err in admitting into evidence prior inconsistent statements made to the police by one witness; and (3) the trial justice properly denied Defendant’s motion for a new trial. View "State v. Stokes" on Justia Law

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The Supreme Court affirmed the order of the superior court denying Defendant’s motion to correct his sentence, holding that there was no error on the part of the hearing justice in denying Defendant’s motion to correct his sentence. Defendant pled nolo contendere to domestic murder in the first degree and agreed to habitual offender status in exchange for the dismissal of other counts against him. Defendant was sentenced to life on the domestic murder count and to ten to fifteen years as a habitual offender. On appeal, Defendant argued that his plea agreement was illegal because, as to his habitual offender sentence, the sentencing justice did not set a particular date when Defendant would be eligible for parole. The Supreme Court denied relief, holding that the hearing justice did not err in denying Defendant’s motion to correct his sentence because the statutory language does not require that a sentencing justice set a particular date when a defendant will be eligible for parole. View "State v. Paiva" on Justia Law

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The Supreme Court affirmed the judgments of the superior court adjudging Appellant to be a violator of his probation, holding (1) there was no reason to remand Appellant’s case for a new probation violation hearing under the new standard set forth in accordance with the amended Rule 32(f) of the Superior Court Rules of Criminal Procedure; and (2) the hearing justice did not act arbitrarily or capriciously in finding that Appellant had violated the conditions of his probation. Five years after the judgments of conviction and commitment were entered, Appellant filed petitions for the issuance of writs of certiorari, which the Supreme Court granted. The Court then affirmed the judgments of the superior court, holding (1) the judgments at issue were final in 2016 when Rule 32(f) was amended, and they remained final; and (2) the evidence was sufficient to support the hearing justice’s conclusion that Appellant had breached the terms and conditions of his probation. View "State v. D’Amico" on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree robbery, conspiracy to commit first-degree robbery, and assault with a dangerous weapon in a dwelling house with intent to commit robbery, holding that the trial justice was not clearly wrong when he denied Defendant’s motion for a new trial. After a jury trial, Defendant was convicted. The trial justice denied Defendant’s renewed motion for judgment of acquittal and motion for new trial, in which Defendant argued that the jury’s verdict was contrary to the weight of the evidence. The Supreme Court affirmed the trial justice’s denial of Defendant’s motion for new trial, holding that the trial justice did not overlook or misconceive any material evidence and did not err in denying the motion. View "State v. Johnson" on Justia Law

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The Supreme Court quashed the judgment of the superior court that granted Defendant’s application for postconviction relief and reinstated Defendant’s convictions, holding that the hearing justice erred in holding that trial counsel rendered ineffective assistance in certain respects. The Supreme Court reinstated Defendant’s conviction with respect to aiding-and-abetting counts for felony murder, robbery, using a firearm in the commission of a crime o violence, discharging a firearm in the commission of a crime of violence, and committing a crime of violence while armed and having available a firearm. Specifically, the Supreme Court held (1) trial counsels’ performance was not deficient in failing to propose aiding-and-abetting jury instructions in line with Rosemond v. United States, 572 U.S. 65 (2014), because that case was inapplicable here; and (2) the hearing justice erred when she held that trial counsel rendered ineffective assistance by failing to challenge the sufficiency of the evidence with respect to an aiding-and-abetting theory. View "Whitaker v. State" on Justia Law

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The Supreme Court affirmed Defendant’s conviction of one count of first-degree child molestation sexual assault, holding that none of the superior court justice’s challenged evidentiary rulings warranted reversal. Specifically, the Court held (1) Defendant waived his argument that the trial justice erred in allowing testimony concerning other alleged incidents of sexual assault, in violation of R.I. R. Evid. 403 and 404(b); (2) Defendant failed to preserve his objection to the trial justice’s rulings limiting defense counsel’s cross-examination of a witness, and even if the trial justice erred, such error would have been harmless beyond a reasonable doubt; and (3) Defendant waived his argument that the trial justice erred in allowing hearsay testimony into evidence. View "State v. Colon" on Justia Law

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The Supreme Court affirmed Defendant’s conviction of two counts of second-degree child molestation sexual assault, holding that the trial justice did not err in denying Defendant’s motion for a new trial. On appeal, Defendant argued that the evidence presented at trial raised serious doubt about the allegations and that the trial justice overlooked and misconceived material evidence. The Supreme Court disagreed, holding (1) the trial justice conducted an appropriate analysis of the evidence presented, evaluated the credibility of the witnesses, and assessed the weight of the evidence; (2) the trial justice did not err in determining that sufficient credible evidence was submitted to support the verdict on both counts; and (3) therefore, the trial justice did not err in denying Defendant’s motion for a new trial. View "State v. Tabora" on Justia Law

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The Supreme Court affirmed Defendant’s conviction for first-degree child abuse, holding that the trial justice did not err by requiring a licensed clinical social worker to testify about statements Defendant made to her while seeking mental-health treatment. A dispositive issue on appeal was whether any privilege arising from the Confidentiality of Health Care Information Act, R.I. Gen. Laws 5-37.3, is abrogated by R.I. Gen. Laws 40-11-11. The Supreme Court affirmed, holding (1) section 40-11-11 unambiguously abrogates all privileges that might otherwise attach to communications between any professional person and her patient in situations involving known or suspected child abuse or neglect; and (2) this nullification of such privileges in judicial proceedings includes criminal proceedings. View "State v. LeFebvre" on Justia Law

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The Supreme Court affirmed Defendant’s conviction of reckless driving, holding that the trial justice did not commit clear error or overlook or misconceive material or relevant evidence in denying Defendant’s motion for a new trial. In his motion for a new trial, Defendant argued that the evidence presented at trial was insufficient to convict him of reckless driving and that the jury did not note the specific location where Defendant’s alleged reckless driving took place. The trial justice denied the motion. The Supreme Court affirmed, holding that the trial justice did not clearly err or misconceive material evidence and did not err in denying Defendant’s motion for a new trial. View "State v. Silva" on Justia Law