Justia Criminal Law Opinion Summaries

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

The Supreme Court affirmed the judgment of the superior court finding Defendant guilty of second-degree child abuse, holding that no prejudicial error occurred in the proceedings below.Specifically, the Court held (1) to the extent that certain testimony may have been improperly admitted, it was harmless; (2) the trial justice clearly articulated a basis for his fining that the injury requirement of the second-degree child abuse statute had been met, and therefore, the court need not reach the question of a lesser-included offense; and (3) the trial justice did not err by denying Defendant’s motion for a new trial. View "State v. Cahill" on Justia Law

The Supreme Court vacated in part and affirmed in part Defendant’s five criminal convictions, holding that Defendant’s convictions of two counts of sex trafficking of a minor in violation of R.I. Gen. Laws 11-67-6 must be vacated because section 11-67-6, which has since been repealed and replaced with R.I. Gen. Laws 11-67.1-3, failed to charge an offense.Defendant was convicted of two counts of sex trafficking of a minor, two counts of pandering or permitting prostitution, and one count of driving a motor vehicle with a suspended license. The Supreme Court held (1) Defendant’s convictions for sex trafficking of a minor must be vacated because the statute under which Defendant was charged under failed to charge an offense; (2) the trial justice did not err in refusing to order an amended bill of particulars on the eve of trial; and (3) the district court did not abuse its discretion in refusing to grant a mistrial when a witness disclosed that she had learned about human trafficking during a conversation with Defendant in which he discussed returning to prison. View "State v. Footman" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting the State’s motion for summary judgment and denying Appellant’s petition for a writ of certiorari, holding that the hearing justice did not err in granting summary judgment.In his application for postconviction relief, Appellant alleged that the indictment in his case was improperly amended, that he was improperly sentenced as a habitual offender, and that his trial attorney was ineffective. The hearing justice granted summary judgment for the State. The Supreme Court affirmed, holding that there was no reversible error in the granting of summary disposition in the State’s favor. View "Ricci v. State" on Justia Law

The Supreme Court vacated the judgment of the superior court dismissing Appellant’s application for postconviction relief, holding that Appellant was not afforded counsel in accordance with Shatney v. State, 755 A.2d 130 (R.I. 2000).After Appellant was convicted, he filed an application for postconviction relief. A justice of the superior court appointed counsel to represent him. After examining Appellant’s claims, counsel moved to withdraw from the case. The hearing justice granted the motion, concluding that Appellant’s claims lacked merit. The hearing justice then denied Appellant’s application for postconviction relief. The Supreme Court vacated the judgment below, holding that, after counsel’s motion to withdraw was granted, Appellant was not provided with a meaningful opportunity to reply to the hearing justice’s proposed dismissal of his application for postconviction relief. View "Hernandez v. State" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of second-degree sexual assault, holding that even if Defendant’s issue on appeal had been properly preserved for appellate review, no reversible error occurred.On appeal, Defendant argued that the trial judge erred by allowing testimony by the responding officer in which he commented on the complaining witness’s credibility. Specifically, Defendant argued that this testimony was impermissible bolstering or vouching of the witness’s credibility. The Supreme Court affirmed, holding (1) Defendant failed properly to preserve his objection for appeal because he did not provide a specific basis for the objection at trial; and (2) the admission of the testimony did not constitute prejudicial error. View "State v. Dalton" on Justia Law

The Supreme Court affirmed the order of the superior court denying Defendant’s motion to reduce a sentence, holding that the trial justice was within his discretion to give and confirm the punishment for Defendant.Defendant was convicted of one count of first-degree child molestation sexual assault. Defendant was originally sentenced to a forty-year term to serve but, after the case was remanded, he was sentenced to life imprisonment. Defendant filed a motion to reduce the sentence, arguing that the life sentence imposed after the second trial was unconstitutional. The trial justice denied the motion. Defendant appealed, arguing that the trial justice abused his discretion by imposing a sentence significantly longer than the sentence imposed after his first conviction. The Supreme Court affirmed, holding that the trial justice properly decided to impose the maximum sentence permitted under the statute in this case and that Defendant failed to demonstrate that the sentence was grossly disparate from other sentences generally imposed for similar offenses. View "State v. Oliveira" on Justia Law