Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the trial court convicting Defendant for the second-degree murder of his girlfriend’s six-year-old son.On appeal, Defendant claimed that he was entitled to a new trial because the trial justice erred in instructing the jury and in admitting certain testimony at trial. The Supreme Court disagreed, holding (1) the trial justice did not err with respect to her instruction on second-degree felony murder; (2) the trial justice did not err with respect to her instruction on causation; and (3) the trial justice did not err in allowing the challenged testimony once Defendant opened the door to its relevancy. View "State v. Pati" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of murder and discharging a firearm while committing a crime of violence, among other crimes.Specifically, the Court held (1) Defendant’s argument that the trial justice erred by allowing a Providence police detective to offer a lay opinion regarding the location of a particular cell phone at a certain point in time was waived because Defendant did not object at trial; and (2) the trial justice did not err by denying Defendant’s motion for a new trial based on the weight of the evidence. View "State v. Moten" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying postconviction relief for Appellant, who challenged the trial court’s acceptance of his nolo contendere plea on a second-degree murder charge.At sentencing, the hearing justice sentenced Appellant to the maximum sentence under the “capped” plea agreement - sixty years’ imprisonment, with twenty years suspended with probation following Appellant’s release. Appellant later filed a pro se application for postconviction relief arguing that he received ineffective assistance of counsel and that the hearing justice failed adequately to explain Appellant’s waiver of constitutional rights when he pled nolo contendere. The superior court denied relief. The Supreme Court affirmed, holding (1) the postconviction relief justice did not overlook or misconceive material evidence, nor did she clearly err in denying Appellant’s postconviction relief application; and (2) any issues related to Shatney v. State, 755 A.2d 130 (R.I. 2000), were cured in this case. View "Navarro v. State" on Justia Law

The Supreme Court vacated Defendant’s convictions on count four, sex trafficking of a minor, in violation of R.I. Gen. Laws 11-67-6, and count six, conspiring to commit the crime of sex trafficking with a minor, holding that a gap in the language of section 11-67-6 rendered it unenforceable.Specifically, the Supreme Court held that the gap in section 11-67-6(b) was a statutory flaw that could not be repaired without the addition of language that criminalizes the conduct described in the statute, which is a task that goes beyond statutory construction. Therefore, the Court held that section 11-67-6 failed to state a crime, and therefore, Defendant’s motion to dismiss counts four and six of the indictment should have been granted. The dissent would affirm the convictions on counts four and six, holding that the statute did not involve the son of legislative commission that required a reversal of Defendant’s conviction because the statute, “for all its lack of absolute perfection in terms of draftsmanship,” sufficed to give fair and adequate notice. View "State v. Maxie" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of felony assault following a jury-waived trial.On appeal, Defendant argued (1) there was sufficient evidence of self-defense to require a finding of not guilty, and (2) the trial justice overlooked material evidence in carrying out his fact-finding function. The Supreme Court disagreed, holding (1) the state successfully rebutted Defendant’s self-defense claim beyond a reasonable doubt; and (2) there was no error in Defendant’s trial. View "State v. Lussier" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of murder, conspiracy to commit murder, and discharging a weapon while committing a crime of violence.On appeal, Defendant argued that the trial justice abused his discretion in denying his motions to pass and in overruling his objections to photographic evidence and erred in denying his motion for a new trial. The Supreme Court disagreed, holding (1) the trial justice did not err in denying Defendant’s motions to pass and motions for mistrial; (2) the trial justice did not abuse his discretion in admitting the photograph at issue; and (3) Defendant’s disagreement with the trial justice’s credibility determination was an insufficient basis for reversal. View "State v. Alexis" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of two counts of first-degree sexual assault.On appeal, Defendant argued, among other things, that the trial justice should have granted his motion for a mistrial due to what he termed the prosecutor’s comment on his failure to testify. The Supreme Court held (1) the trial justice correctly found that the prosecutor’s statement, taken in context, did not improperly comment on Defendant’s failure to testify and thus did not violate Defendant’s Fifth Amendment rights; (2) the trial justice did not commit reversible error in admitting Defendant’s “mug shot” into evidence; and (3) the trial justice did not err by denying Defendant’s motion for new trial. View "State v. Marizan" on Justia Law

The Supreme Court vacated the judgment of the superior court denying Petitioner’s application for postconviction relief, in which he alleged that his constitutional rights were violated when his parole was revoked and he was denied the possibility of parole in the future.After Petitioner was granted parole, he was arrested in Pennsylvania and convicted of one count of aggravated assault. In 1994, while Petitioner was serving his sentence in Pennsylvania, the Rhode Island Parole Board voted to revoke Petitioner’s parole and indicated that he would no longer be eligible for parole. Upon completion of his prison term in Pennsylvania, Petitioner, in 2014, appeared again before the Parole Board. The Parole Board affirmed the revocation of Petitioner’s parole and stated that Petitioner would forever remain ineligible for parole consideration. The Supreme Court held that it was error for the Parole Board to have denied Petitioner counsel at the 1994 hearing and the 2014 hearing and remanded the case with instructions that the superior court remand this case to the Parole Board to conduct a new parole revocation hearing. View "Jefferson v. State" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of two counts of first-degree child molestation sexual assault, for which Defendant received two concurrent forty-year sentences.On appeal, the Court held that the trial justice did not err by (1) refusing to the testimony of Natalie Kissoon, M.D. in its entirety for lack of foundation; (2) refusing to grant Defendant’s motion to pass the case after Dr. Kissoon testified that the victim’s disclosures were consistent with sexual abuse; and (3) denying Defendant’s motion for a new trial based upon newly discovered evidence. View "State v. Rathbun" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Defendant’s application for postconviction relief in which Defendant argued that he had received ineffective assistance of counsel because his lawyer was not licensed to practice law in Rhode Island.Defendant pled nolo contendere to two criminal offenses and admitted to violating his probationary sentence. In his postconviction relief application, Defendant argued that he received ineffective assistance of counsel because his defense counsel, who was not licensed to practice law in Rhode Island, was engaging in unlawful conduct. Defendant further argued that his defense counsel’s associate, who was licensed in Rhode Island and who appeared in court with Defendant, was a “straw man” and thus complicit in the scheme to practice law without a license. The superior court denied the application. The Supreme Court affirmed, holding (1) the trial justice properly found that defense counsel’s associate, not defense counsel, represented Defendant with respect to his pleas; and (2) Defendant’s argument that defense counsel and the associate had a conflict of interest in representing Defendant lacked merit. View "Millette v. State" on Justia Law