Justia Criminal Law Opinion Summaries

Articles Posted in Rhode Island Supreme Court
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The Supreme Court vacated Defendant's judgment of conviction on one count of first-degree child molestation sexual assault and remanded the case to the superior court for a new trial, holding that the trial justice erred in denying Defendant's motion to pass the case after the prosecutor's statements during closing argument about Defendant's courtroom demeanor and behavior toward the complainant. Specifically, the Court held (1) the prosecutor's statements regarding Defendant's courtroom demeanor had the potential for unfair prejudice, and a curative instruction could not overcome the prejudice in this case; (2) the trial justice erred in admitting some, but not all, of the evidence pertaining to a police investigation into Defendant for possession of child pornography; and (3) Defendant's claim that the trial justice erred in failing to safeguard Defendant's right to a fair trial based on various claims related to the presence of members of a motorcycle group known as Bikers Against Child Abuse in the courtroom during trial was not properly before the court. View "State v. Bozzo" on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree murder and first-degree arson, holding that the trial justice was not clearly wrong in denying Defendant's motion for a new trial. On appeal, Defendant argued that the trial justice was clearly wrong when she denied his motion for a new trial because the weight of the evidence did not support the jury's verdict. The Supreme Court affirmed, holding that the evidence supported a finding that Defendant was the perpetrator and that the verdict was not against the weight of the evidence because the evidence supported a finding of premeditation. View "State v. Gumkowski" on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of domestic assault with a dangerous weapon, holding that the trial justice did not abuse her discretion in her evidentiary rulings. On appeal, Defendant argued that the trial justice erred by granting two of the State's motions in limine precluding the jury from hearing evidence of the victim's arrest for gun charges and viewing videos of the victim having engaged in acts of violence. The Supreme Court affirmed, holding that the trial justice did not abuse her discretion when she (1) prevented any mention that Defendant had been arrested on the gun charges, and (2) excluded the videos. View "State v. Medina" on Justia Law

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The Supreme Court affirmed Defendant's conviction of assault with a dangerous weapon in a dwelling house and other offenses, holding that the trial justice did not err in admitting a recording and transcript of a phone call between Defendant and a confidential informant into evidence and did not clearly err by failing to grant a mistrial when it became evidence that defense counsel did not possess or review the complete discovery package prior to trial. Specifically, the Court held (1) the trial justice did not abuse his discretion when he admitted the transcript of the phone call into evidence; (2) there was not clear error in the trial justice's finding that Defendant was not prejudiced by not having certain materials priorate trial; and (3) having found no abuse of discretion when denying the mistrial, there is no reason to overturn the trial justice's denial of a motion for a new trial for the same reasons. View "State v. Rivera" on Justia Law

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The Supreme Court affirmed Defendant's conviction of four counts of first-degree sexual assault, holding that the trial justice did not err when he did not declare a mistrial after the prosecutor made "ill advised" statements that were not prejudicial to Defendant. On appeal, Defendant argued that the trial justice erred by failing to grant his motion to pass the case after the prosecutor made an improper remark during her closing argument by briefly referring to the Adult Correctional Institutions (ACI) and after the prosecutor improperly vouched for the credibility of the victim during her closing argument. The Supreme Court affirmed, holding (1) the prosecutor's reference to the ACI was improper, but the comment was not so prejudicial that the trial court's failure to grant a mistrial was an abuse of discretion; and (2) any potential prejudice to Defendant arising from the prosecutor's comment relating her personal experience during her closing argument did not render the proceedings unfair. View "State v. Belen" on Justia Law

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The Supreme Court affirmed the judgment of the superior court denying Defendant's motion to reduce or correct an illegal sentence, holding that, under the circumstances of this case, the trial court did not err in denying the motion despite the fact that the judgment of conviction did not conform to the oral sentence. In his motion, Defendant conceded that the original sentence imposed was not an illegal sentence but that the error arose from the manner in which the sentence was executed. Specifically, under the law in effect at the time, Defendant was eligible to appear before the parole board after ten years' imprisonment, but it wasn't until eighteen years later that he was first deemed eligible to appear before the parole board. The trial justice denied the motion because Defendant's sentence was not illegal. The Supreme Court affirmed, holding that relief was not available to Defendant. View "State v. Mattatall" on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree sexual assault, holding that the trial justice did not abuse its discretion in admitting certain text messages because the evidence was properly authenticated under R.I. R. Evid. 901. The text messages at issue were allegedly sent by Defendant to the complainant. Defendant argued on appeal that because the State did not produce either direct evidence or evidence of distinctive characteristics of the text messages, it did not establish that the text messages were written by Defendant and therefore did not properly authenticate the evidence in accordance with Rule 901. The Supreme Court affirmed, holding that the State produced sufficient circumstantial evidence to establish that Defendant authored the text messages, and therefore, the evidence was properly authenticated under Rule 901. View "State v. Mulcahey" on Justia Law

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In this case stemming from an incident that allegedly took place while Plaintiff was held in pretrial detention at the Adult Correctional Institutions (ACI) the Supreme Court affirmed the judgment of the superior court in favor of Defendants following entry of an order that denied Plaintiff's motion to file a second amended complaint, holding that Plaintiff was not entitled to relief on his allegations of error. In his complaint, Plaintiff, who was serving consecutive sentences of life imprisonment, alleged that he was attacked by a fellow inmate and that the attack was made possible by a correctional officer. Plaintiff sued ACI, the state, and various John Does, alleging negligence for failing properly to protect him. The trial justice granted Defendants' motion to dismiss based on Rhode Island's civil death statute, R.I. Gen. Laws 13-6-1. Thereafter, the trial justice denied Plaintiff's motion to file a second amended complaint. The Supreme Court affirmed, holding (1) the trial justice properly denied Plaintiff's motion to amend; and (2) Plaintiff's arguments that the civil death statute is unconstitutional on various grounds were barred by the "raise-or-waive" rule and procedural law. View "Gallop v. Adult Correctional Institutions" on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of assault with a dangerous weapon and resisting arrest, holding that the trial justice did not err by denying Defendant's motion for a new trial. On appeal, Defendant argued that the trial justice overlooked and misconceived material evidence concerning the charges of assault with a dangerous weapon and resisting arrest and therefore erred by denying his motion for a new trial. The Supreme Court affirmed, holding that where the trial justice complied with the directives contained in Rule 33 of the Superior Court Rules of Criminal Procedure and articulated adequate grounds for denying Defendant's motion for a new trial, the justice did not err in denying the motion for a new trial. View "State v. Neugent" on Justia Law

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The Supreme Court affirmed the order of the superior court denying Defendant's motion to dismiss one count of first-degree sexual assault on the grounds of double jeopardy and prosecutorial misconduct, holding that Defendant was not entitled to relief on his claims. Defendant was found guilty of assault and battery and acquitted as to several offenses, but as to the charge for first-degree sexual assault based upon anal penetration, the jury deadlocked and did not reach a verdict. When it became evident that the State would retry Defendant on the deadlocked count, Defendant filed several pretrial motions. Defendant filed a motion to dismiss the sole remaining count, arguing that double jeopardy barred a retrial of acquitted conduct that arose from the same set of facts previously decided by the jury and that the prosecutor engaged in misconduct. Defendant further sought to exclude any reference to acquitted conduct from the first trial. The trial justice denied Defendant's motions. The Supreme Court affirmed, holding (1) Defendant's first argument conflated a double jeopardy contention with one that was evidentiary, and whether Defendant's acquitted conduct was admissible under R.I. R. Evid. 404(b) at his retrial was an issue not properly before the court; and (2) Defendant's prosecutorial misconduct argument was not preserved for appeal. View "State v. Forlasto" on Justia Law