Articles Posted in Rhode Island Supreme Court

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The Supreme Court affirmed Defendant's conviction of second-degree murder, holding that Defendant waived his argument that the trial justice erred when she failed to instruct the jury on the lesser-included offense of voluntary manslaughter and that the trial justice did not err in refusing to grant a mistrial. Specifically, the Court held (1) Defendant's contention that the trial judge erred in failing to give the jury an instruction on voluntary manslaughter and instead giving an involuntary manslaughter instruction was not properly preserved for appellate review; (2) the trial justice did not err in refusing to declare a mistrial on what Defendant characterized as the prosecutor's "wholly improper" statements made during closing argument because the court's cautionary instruction cured the prejudice created by the prosecutor's comments labeling Defendant as a scam artist, liar, and thief. View "State v. Lastarza" on Justia Law

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The Supreme Court affirmed Defendant's conviction of four counts of first-degree child molestation sexual assault, holding that Defendant was not entitled to a new trial based on any of his arguments on appeal. Specifically, the Court held (1) the trial justice did not err when he accepted a jury waiver form that Defendant had signed outside the presence of the trial justice; (2) Defendant's colloquy with the trial justice demonstrated that Defendant knowingly, intelligently, and voluntarily waived his right to a jury trial; and (3) the trial justice adequately explained the differences between a jury trial and a bench trial. View "State v. Morais" on Justia Law

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In this complaint brought against Rhode Island College and various college officials alleging that Defendants’ conduct toward Plaintiff during his enrollment in the Master of Social Work program due to his political beliefs violated his constitutional rights the Supreme Court vacated in part and affirmed in part the judgment of the hearing justice granting summary judgment in favor of Defendants and dismissing Plaintiff’s claim for punitive damages, holding that summary judgment must be vacated as to certain counts. Specifically, the hearing justice held that Defendants were entitled to summary judgment on Plaintiff’s claims that Defendant violated his constitutional rights to freedom of expression and equal protection, conspired to violate his civil rights, and violated his procedural due process rights. The hearing justice also found that Plaintiff had not established a prima facie case for punitive damages. The Supreme Court held (1) summary judgment was improper as to Plaintiff’s freedom of speech claims; (2) summary judgment was proper as to Plaintiff’s equal protection and procedural due process claims; (3) Defendants were entitled to judgment as a matter of law on Plaintiff’s conspiracy claim; and (4) the hearing justice properly found that Plaintiff had not met his burden to demonstrate a prima facie case for punitive damages. View "Felkner v. Rhode Island College" on Justia Law

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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