Justia Criminal Law Opinion Summaries

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

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

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

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

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

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

The Supreme Court affirmed the judgment of the superior court finding Defendant guilty of one count of second-degree murder and one count of discharging a firearm while committing a crime of violence, holding that the trial justice did not err in denying Defendant’s motion to suppress or in failing to exclude certain evidence.Specifically, the Court held (1) law enforcement’s failure to comply with Miranda does not require the suppression of the physical evidence acquired as a result of a suspect’s unwarned, but voluntary, statements; (2) Defendant’s statements leading detectives to a firearm and ammunition were voluntary, and therefore, the gun and ammunition were admissible; and (3) the trial justice did not err in concluding that the police’s seizure through the impounding of Defendant’s vehicle and the subsequent search of the vehicle were constitutional, and therefore, the evidence obtained therein admissible. View "State v. Beauregard" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Appellant’s application for postconviction relief, holding that Appellant was not entitled to postconviction relief.Appellant was found guilty of murder in the first degree and other offenses and sentenced to life imprisonment. Appellant later filed the instant application for postconviction relief alleging that he was denied effective assistance of trial and appellate counsel. After a hearing, the hearing justice denied the application for postconviction relief. The Supreme Court affirmed, holding that there was no ineffective assistance of either Appellant’s trial or appellate counsel, and therefore, the hearing justice properly denied Appellant’s application for postconviction relief. View "Jimenez v. State" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of second-degree sexual assault for having sexually assaulted a fifteen-year-old neighbor, holding that the trial justice did not commit reversible error.Specifically, the Court held (1) the trial justice did not commit reversible error by sustaining the prosecutor’s objection to defense counsel’s question to the complainant as to whether he had received any professional counseling with respect to the events at issue in this case; (2) Defendant waived his argument that the trial court erred in not striking Defendant’s wife’s response to the prosecutor’s questions about contacting the complainant or his family; and (3) the trial justice did not err in overruling the defense objection to Defendant’s wife’s testimony that she and Defendant lived on the side of an elementary school. View "State v. MacNeil" on Justia Law

The Supreme Court quashed the judgment of the superior court denying Appellant’s application for postconviction relief and remanded the case for further factfinding in light of this Court’s opinion in State v. Gibson, 182 A.3d 540 (R.I. 2018), holding that Gibson controlled the legal issue in this case.In 1993, Appellant was convicted of a sexual offense. Appellant’s duty to register was governed by R.I. Gen. Laws 11-37-16, the registration statute in place at the time of that conviction. Pursuant to the holding in Gibson, however, the duration of the duty to register was controlled by the present version of section 11-37.1-4(a). Because the record on review was inadequate to enable this Court to define the correct contours of the duration of Appellant’s duty to register, the Court quashed the judgment of the superior court and remanded for further proceedings in light of Gibson. View "Atryzek v. State" on Justia Law