Justia Criminal Law Opinion Summaries

Articles Posted in Rhode Island Supreme Court
by
The Supreme Court affirmed the order of the superior court granting Defendant's motion to suppress the statements he made to police at the scene of an automobile collision, holding that the superior court did not abuse its discretion in granting the suppression motion.Specifically, the Supreme Court held (1) the trial justice correctly determined that Defendant was in custody when he made incriminating statements to the law enforcement officer at the scene of the arrest and therefore correctly suppressed the statements Defendant made to the officers at the time; and (2) the state's second contention on appeal was not properly before the Court. View "State v. Corcoran" on Justia Law

by
The Supreme Court affirmed the order of the superior court granting Defendants' motion to dismiss all electronic, wire, or oral communications obtained through the use of wiretaps and any subsequently-obtained evidence in these consolidated cases, holding that the trial justice did not err.In granting Defendants' motion to suppress, the trial justice found that an associate justice of the superior court had no authority to issue the wiretap orders. The State appealed this ruling and argued, alternatively, that the trial justice erred in concluding that suppression of the evidence derived from the wiretap orders was warranted. The Supreme Court affirmed, holding that the trial court correctly concluded that the associate justice was not vested with the statutory authority to administer and sign the wiretap orders and, therefore, that those orders were in violation of R.I. Gen. Laws 12-5.1, the Interception of Wire and Oral Communications Act. View "State v. McGuire" on Justia Law

by
The Supreme Court vacated the decision and order of the superior court declaring Defendant to be in violation of his probation, holding that because Defendant was compliant with court-ordered restitution payments and ran out of time, the remedy could not include incarceration absent a finding of willful violation.Defendant pled nolo contendere to the charge of unlawful appropriation and was ordered to pay restitution. Defendant dutifully paid the amounts set forth in a periodic payment plan but, in anticipation of Defendant's failure to pay restitution in full prior to the expiration of his sentence, the state alleged that Defendant was in violation of his probation. An order subsequently entered declaring Defendant a probation violator. The Supreme Court vacated the decision below, holding that there were other remedies the state could pursue other than incarceration. View "State v. Regan" on Justia Law

by
The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree murder, first-degree robbery, and other crimes, holding that Defendant was not entitled to relief on her allegations of error.On appeal, Defendant argued that the trial justice erred in denying her motion to suppress the evidence found at her apartment, denying her motion to suppress the evidence found in her vehicle, and violating her right to confront a witness. The Supreme Court affirmed, holding (1) there was no error in the trial justice's denial of Defendant's motion to suppress the evidence obtained in the apartment based on insufficient probable cause; (2) the trial justice did not clearly err in denying Defendant's request for a Franks hearing; (3) the warrantless seizure of Defendant's vehicle did not violate her rights under either the State or Federal Constitution; and (4) Defendant's Confrontation Clause argument was waived. View "State v. Hudgen" on Justia Law

by
The Supreme Court affirmed Defendant's conviction of one count of possession of child pornography, holding that the State's interesting protecting children from the sexual exploitation portrayed in the images at issue overwhelmingly outweighed Defendant's "expressive interests" in possessing them.Defendant's conviction arise from his possession of computer hard drives or digital storage media containing seventeen computer files of images. The trial justice concluded that six of the images depicted minors engaging in sexually explicit conduct and, based on the six images, convicted Defendant to one count of possession of child pornography. The Supreme Court affirmed, holding that the images depicted unprotected child pornography within the meaning of R.I. Gen. Laws 11-9-1.3. View "State v. Hansen" on Justia Law

by
The Supreme Court affirmed the judgment of the superior court convicting and sentencing Defendant for one count of resisting arrest, holding that there was no reversible error in the proceedings below.On appeal, Defendant argued that the trial justice committed prejudicial error by failing to instruct the jury on a defense to the charge of resisting arrest, by failing to pass the case following the State's inclusion of certain remarks in its opening statement, and by refusing to allow a certain line of questioning on cross-examination of the arresting officer. The Supreme Court affirmed, holding that Defendant's claims on appeal were without merit. View "State v. Burkinshaw" on Justia Law

by
The Supreme Court affirmed in part and quashed in part the judgment of the superior court granting Defendant's application for postconviction relief and vacated four criminal convictions for failure to register as a sexual offender, holding that Defendant was no longer required to register as a sex offender in Rhode Island.In 1993, Defendant entered a guilty plea to rape and abuse of a child and was later released. Thereafter, on four separate occasions, the state charged Defendant with failure to register as a sex offender, which led to Defendant's pleas of nolo contendere. Defendant subsequently sought postconviction relief arguing that he was not under an obligation to register as a sex offender at the time of the charged offenses. On remand, the trial court concluded that Defendant had no duty to register as a sex offender and vacated his convictions for failure to register. The Supreme Court quashed the portion of the judgment that vacated Defendant's convictions for his 2009 and 2010 offenses and otherwise affirmed, holding that Defendant was under no obligation to register as a sex offender in Rhode Island. View "Atryzek v. State" on Justia Law

by
The Supreme Court affirmed the judgment of the superior court convicting Defendant of second-degree sexual assault, breaking and entering, and disorderly conduct following a jury trial, holding that the trial justice did not err in denying Defendant's motion for a new trial.On appeal, Defendant argued that the trial justice erroneously denied his motion for judgment of acquittal on the count alleging disorderly conduct and in denying his motion for new trial on all convicted counts. The Supreme Court disagreed, holding that the trial justice properly exercised its independent judgment, did not err in analyzing the evidence presented, did not overlook or misconceive certain testimony, and articulated adequate reasons for denying Defendant's motion for a new trial based on the weight of the evidence. View "State v. Valdez" on Justia Law

by
The Supreme Court affirmed the judgment of the superior court in favor of the Rhode Island Department of the Attorney General upholding a determination by the Sex Offender Board of Review classifying Petitioner as a Risk Level III sex offender under the Sexual Offender Registration and Community Notification Act, R.I. Gen. Laws 37.1, holding that there was no error.Petitioner pled guilty to three felony counts of distributing, receiving, and possessing child pornography. After Petitioner was released from custody, the Board classified him as a high-level Level III offender. On appeal, Petitioner argued that his sex offender classification was improper because the Board "unreasonably and arbitrarily" overstated his risk level and erred by failing to disclose what material it utilized beyond risk-assessment tools to establish his level of risk. The Supreme Court affirmed, holding that Petitioner failed to show that the Board's classification of him was not in compliance with the law. View "Matteson v. R.I. Department of Attorney General" on Justia Law

by
The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of second-degree child molestation following a jury trial, holding that there was no abuse of discretion on the part of the trial justice with respect to the admission of testimony from a physician and from Defendant's brother-in-law.Specifically, the Supreme Court held (1) the trial justice did not commit reversible error by allowing the testimony of a physician testifying as an expert witness with respect to four statements with which Defendant took issue; and (2) Defendant's contentions with respect to the cross-examination of his brother-in-law were waived. View "State v. Benitez" on Justia Law