Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the order of the superior court denying Defendant's motion to correct sentence pursuant to Rule 35 of the Superior Court Rules of Criminal Procedure, holding that the trial justice did not err in denying Defendant's motion to correct sentence.In 2006, Defendant was convicted of first- and second-degree child molestation sexual assault. From 2004 until his determination of guilt in 2006, Defendant was on "electronic home confinement" as a condition of bail. Following the completion of his direct and postconviction relief appeals Defendant filed a pro se motion for correction of sentence, arguing that the twenty-four months he spent on home confinement should be credited toward his overall sentence pursuant to R.I. Gen. Laws 12-19-2(a). The trial court denied Defendant's motion. The Supreme Court affirmed, holding (1) the trial justice correctly ruled that Defendant should not be credited with the time he spent on home confinement; (2) Defendant waived his equal protection argument; and (3) the trial justice did not abuse her discretion in denying Defendant's request for counsel in connection with his motion to correct sentence. View "State v. Merida" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of first degree robbery and one count of conspiracy to commit robbery, holding that the admission of an out-of-court statement made by an alleged coconspirator who did not appear at Defendant's trial, was harmless beyond a reasonable doubt.While the sole issue on appeal was whether Defendant's Sixth Amendment confrontation rights were violatedl. The Court held (1) this Court assumes, without deciding, that a Confrontation Clause objection was properly articulated; and (2) because the remaining evidence was sufficiently compelling to support the jury's finding of guilty, the admission of the coconspirator's out-of-court declaration was harmless beyond a reasonable doubt. View "State v. Sanchez" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Defendant's motion for a new trial after convicting Defendant of of assault and battery resulting in serious bodily injury and possession of a knife with a blade of more than three inches, holding that the trial justice did not err in denying Defendant's motion for a new trial.In his motion for a new trial, Defendant argued that the trial justice overlooked and misconceived material evidence when he agreed with the jury's verdict because the trial justice did not take into account that Defendant had to appreciate that he knowingly had an opportunity to retreat in safety. The Supreme Court disagreed, holding that the trial justice more than adequately performed his role under each step of the analysis of Defendant's motion for a new trial. View "State v. Guerrero" on Justia Law

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

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

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

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

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

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

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