Justia Criminal Law Opinion Summaries

Edward Mather, the defendant, was charged with multiple counts of domestic assault, vandalism, and violation of a no-contact order. Following his arraignment, he was ordered to undergo a psychiatric evaluation to determine his competency to stand trial. The evaluation concluded that Mather was incompetent to stand trial and required hospitalization. Subsequently, he was committed to an outpatient facility, LaBelle House Group Home, under the custody of the Department of Behavioral Healthcare, Developmental Disabilities and Hospitals (BHDDH).The Superior Court held a commitment hearing and based on a report from BHDDH, found Mather remained incompetent to stand trial. The court ordered Mather to remain committed to BHDDH's custody but allowed him to be placed in an outpatient facility without endangering himself or others. The court also ordered that if Mather violated the conditions of the order, engaged in threatening or aggressive behavior, or required hospitalization, he should be immediately returned to Eleanor Slater Hospital.Mather filed a petition to discharge from the detention order of commitment in both of his pending criminal matters. He argued that his continued institutionalization at the outpatient facility restricted his liberty and violated due process. The trial justice denied Mather's petitions, reasoning that his commitment to the outpatient facility did not constitute "detention" pursuant to the relevant statute. Mather sought review of the decision, and the Supreme Court of Rhode Island granted the petitions, consolidated the cases for review, and issued the writ.The Supreme Court of Rhode Island quashed the orders of the Superior Court and remanded the matter for further proceedings. The court held that the trial justice committed a reversible error of law when he denied the petitions to discharge from detention orders of commitment. The court concluded that Mather's continued commitment no longer bore a reasonable relationship to the purpose of his commitment under the relevant statute. The court held that where a defendant is found to be incompetent to stand trial and competency is nonrestorable prior to the statutory dismissal period, the defendant is entitled to be discharged from detention under the order of commitment thirty days thereafter. View "State v. Mather" on Justia Law

This case involves four individuals, Joao Neves, Keith Nunes, Pablo Ortega, and Mario Monteiro, who were convicted of various crimes in Rhode Island and were serving multiple sentences, including life sentences. The issue at hand is the interpretation of a Rhode Island statute, G.L. 1956 § 13-8-13(e), which was enacted in 2021 and provides that any person sentenced for any offense committed prior to their twenty-second birthday, other than a person serving life without parole, shall be eligible for parole review after serving no fewer than twenty years' imprisonment.The state argued that the statute applies only to individuals serving a single sentence and does not require the aggregation of multiple sentences for parole eligibility. The respondents, on the other hand, argued that the statute applies to "any offense," and thus requires the aggregation of multiple sentences, including consecutive sentences, for parole eligibility.The trial justice agreed with the respondents and ordered that each respondent be immediately released on parole. The state appealed, arguing that the trial justice's interpretation of the statute violated the separation-of-powers doctrine by modifying judicial sentences.The Supreme Court of Rhode Island held that the statute mandates the aggregation of a qualified offender’s sentences, including consecutive sentences, for parole eligibility. The court also concluded that the statute, as interpreted, does not violate the separation-of-powers doctrine. However, the court found that the trial justice erred in ordering each respondent to be immediately released on parole, as the statute only provides a qualified offender the opportunity to appear before the parole board, not the right to be paroled. The court affirmed in part and vacated in part the judgments of the lower court, and remanded the cases to the parole board for further proceedings. View "Neves v. State of Rhode Island" on Justia Law

The defendant, Dari Garcia, was charged with fifteen counts related to a series of events that occurred on August 17, 2014, at a home in North Providence, Rhode Island. These events resulted in the death of Richard Catalano and injuries to Lorie Catalano and Christopher Tamelleo. The charges included first-degree murder, discharging a firearm while committing a crime of violence, conspiracy, burglary, felony assault, using a firearm during a crime of violence, carrying a firearm without a license, possession of a firearm after conviction of a crime of violence, alteration of marks of identification on a firearm, and committing a crime of violence when possessing a stolen firearm.The case was tried in the Superior Court for Providence County. During the trial, the defendant moved to suppress his verbal statements made to a Rhode Island Deputy Sheriff while he was undergoing treatment at a hospital, arguing that the inquiry constituted custodial interrogation. The trial justice denied the motion. The defendant also filed a motion to dismiss one of the counts on double jeopardy grounds, but the trial justice did not rule on this motion at that time. After a trial, the jury found the defendant guilty on thirteen of the fifteen counts. The defendant subsequently filed a motion for a new trial, which was denied by the trial justice. The defendant was sentenced to multiple terms of imprisonment, including three life sentences.On appeal to the Supreme Court of Rhode Island, the defendant raised several issues, including whether the trial justice erred in allowing the state to strike a prospective juror, whether the trial justice erred in allowing certain testimony, whether the trial justice erred in limiting the cross-examination of a witness, whether the trial justice erred in allowing two brothers to testify in the presence of the jury, whether the trial justice impermissibly aided the prosecution, whether the defendant's convictions violated the double jeopardy clause, whether certain statements made by the prosecutor in her closing argument were unduly prejudicial, and whether the trial justice's sentencing of the defendant resulted in a "de facto life without parole sentence."The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. The court held that the trial justice did not err in her handling of the various issues raised by the defendant. The court also held that the defendant's sentence did not violate the double jeopardy clause and that the prosecutor's statements in her closing argument were not unduly prejudicial. The court further held that the defendant's argument that he received a "de facto life without parole sentence" was not properly preserved for appeal. View "State v. Garcia" on Justia Law

The defendant, Anton Liverpool, was convicted for violating the terms of his probation following a hearing in the Superior Court of Rhode Island. The violation was based on an incident where Liverpool was accused of disorderly conduct. A woman reported to the Providence police that she encountered Liverpool exposing himself and engaging in masturbation while she was walking to work. She also reported that he followed her and continued to expose himself. The police apprehended Liverpool less than an hour later and conducted a show-up identification procedure, where the woman identified Liverpool as the man from her encounter.The Superior Court conducted a two-day violation hearing based on Liverpool's two prior convictions. The state presented evidence from the woman and a police officer. The woman testified about her interaction with Liverpool, described his appearance, and made an in-court identification of him. She also reviewed two surveillance videos of her interaction with Liverpool. The police officer testified about his response to the woman's 911 call, his review of the footage, and his apprehension of Liverpool. Liverpool did not present any evidence. The trial justice found that the state had demonstrated that Liverpool failed to keep the peace and maintain good behavior, thereby violating the terms of his probation.Liverpool appealed the decision, arguing that the trial justice erred in admitting video footage that lacked the required foundation and violated the Confrontation Clause of the Sixth Amendment. He also argued that the trial justice erred in relying on a suggestive show-up identification conducted by the Providence police. The Supreme Court of Rhode Island affirmed the judgment of the Superior Court, concluding that the trial justice did not err in his determination. The court found that there was ample credible evidence upon which the trial justice based his finding, and that the trial justice properly considered the record evidence in determining that Liverpool violated the terms of his probation. View "State v. Liverpool" on Justia Law

The case involves Marklyn Brown, who was arrested and indicted for a shooting that resulted in the death of Ms. Berta Pereira-Roldan. During his seven-hour interrogation at the Providence Police Department, Brown consistently maintained his innocence and expressed his desire to speak with his mother. After three hours of questioning, the police allowed Brown to speak with his mother. The conversation between Brown and his mother was recorded and listened to by the police without their knowledge.The Superior Court heard Brown's motions to suppress the statements he made during the interrogation and the recorded conversation with his mother. Brown argued that his Fifth Amendment right against self-incrimination, his Sixth Amendment right to counsel, and his right under article 1, section 13 of the Rhode Island Constitution against self-incrimination were violated. He also argued that the surreptitious recording violated the Fourth Amendment to the United States Constitution, the Rhode Island Constitution, and constituted an unauthorized wiretap pursuant to G.L. 1956 § 11-35-21. The trial justice suppressed both the interrogation and Brown's entire conversation with his mother, determining that Brown had a reasonable expectation of privacy when he spoke to his mother in the interview room.The Supreme Court of Rhode Island affirmed the order of the Superior Court. The court concluded that Brown had a reasonable expectation of privacy when he spoke with his mother in the interview room, and that the police violated Brown's Fourth Amendment rights as well as his rights pursuant to article 1, section 6 of the Rhode Island Constitution when they recorded his conversation with his mother. The court rejected the state's arguments that Brown did not possess a reasonable expectation of privacy because he did not ask for a private, unrecorded conversation, and that he lacked a reasonable expectation of privacy in a police interrogation room. View "State v. Brown" on Justia Law

Danielle LeFebvre was convicted of first-degree child abuse after her seven-week-old son suffered life-threatening injuries. LeFebvre claimed that her son's injuries were accidental, resulting from a fall from her bed. However, medical examinations revealed complex skull fractures, brain contusions, and rib fractures consistent with abuse. LeFebvre was sentenced to twenty years in prison, with eighteen years to serve and the balance suspended, with probation. She appealed her conviction, but it was affirmed.LeFebvre then filed an application for postconviction relief, arguing that she was deprived of effective assistance of counsel. She claimed her trial counsel failed to consult and present a medical expert at trial and disclosed harmful information to the prosecution. The Superior Court denied her application, finding that her counsel's decision to disclose her medical records was a tactical one and that the absence of expert testimony did not deprive LeFebvre of effective assistance of counsel.LeFebvre appealed to the Supreme Court of Rhode Island, which affirmed the judgment of the Superior Court. The court found that while the disclosure of LeFebvre's medical records was objectively unreasonable, it did not deprive her of a fair trial given the overwhelming evidence of her guilt. The court also found that the failure to consult and present an expert at trial did not satisfy the criteria for ineffective assistance of counsel. View "LeFebvre v. State" on Justia Law

The defendant, Victor Tavares, was convicted by a jury on two counts of first-degree sexual assault and one count of conspiracy to commit first-degree sexual assault. The charges stemmed from an incident that occurred at a party in 2012, where Tavares and another man, Franklin Johnson, were accused of sexually assaulting a woman named Mary. The evidence against Tavares included Mary's testimony, a used condom found at the scene, and DNA evidence linking Johnson to the condom. Tavares, who represented himself at trial and on appeal, raised twelve issues for consideration.Before the Supreme Court of Rhode Island, Tavares argued that the trial court erred in several ways, including by not dismissing the indictment based on the rule of consistency, the doctrine of collateral estoppel, and the General Assembly's lack of authority to enact criminal laws. He also claimed that the trial court improperly conducted voir dire and allowed the introduction of Johnson's DNA evidence.The Supreme Court rejected all of Tavares's arguments. It held that the trial court properly conducted voir dire and correctly allowed the introduction of Johnson's DNA evidence. The court also found that the General Assembly had the authority to enact the criminal laws under which Tavares was charged and convicted. Furthermore, the court ruled that the doctrines of collateral estoppel and the rule of consistency did not apply in this case. Therefore, the Supreme Court affirmed Tavares's conviction. View "State v. Tavares" on Justia Law

In this case decided by the Supreme Court of Rhode Island, the defendant, Mark Chez, appealed his conviction for carrying a pistol without a license. The case stemmed from an incident on May 30, 2020, when a police officer, in an unmarked police car, observed Chez in a suspicious situation. The officer recognized Chez as having outstanding arrest warrants. When the police moved towards the vehicle where Chez was seated, Chez fled, during which the officer observed him throw an object, believed to be a firearm, from his pocket. A police dog subsequently located a firearm in the area where the officer saw Chez discard the object.Chez was charged, tried, and convicted of carrying a pistol without a license. On appeal, Chez argued that the trial justice erred in denying his motion for a judgment of acquittal and his motion for a new trial, contending that the evidence was insufficient to support his conviction, and that the weight of the evidence did not support the jury's verdict.The Supreme Court, after a de novo review of the evidence, held that there was more than sufficient evidence to support a reasonable inference of guilt beyond a reasonable doubt. The court noted that Chez was recognized by multiple officers, was observed running away from the police with a weighted object in his pocket, and that a firearm was discovered in the specific area where an officer observed him throw the object. Accordingly, the Supreme Court affirmed the judgment of the Superior Court, upholding Chez's conviction. View "State v. Chez" on Justia Law

In this case heard by the Supreme Court of Rhode Island, Somayina Odiah, the defendant, was appealing his conviction for one count of indecent solicitation of a child. The defendant had been communicating online with a person he believed to be a 14-year-old transitioning from male to female named “Alice.” However, “Alice” was a fictitious character created by the Rhode Island State Police for an undercover operation. The defendant was arrested after arranging to meet “Alice” in person. The defendant's argument on appeal focused on the claim that the state had not proven that “Alice” was “over the age of fourteen,” a necessary element for the charged offense.The Supreme Court of Rhode Island affirmed the conviction. It held that even if “Alice” had turned fourteen on the day of the charged offense, under Rhode Island law, a person reaches their next year in age at the first moment of the day prior to the anniversary date of their birth. Therefore, “Alice” would have been considered to be exactly fourteen years old on the day before the charged offense. The court concluded that the defendant was planning to meet a fourteen-year-old child, with whom he had communicated about sexual activity, and that the trial justice did not err in denying the motion to dismiss the charge on the basis of the state not proving "Alice" was "over the age of fourteen." Thus, the defendant's judgment of conviction was affirmed. View "State v. Odiah" on Justia Law

The Supreme Court vacated the orders of the superior court granting Defendants' motions to suppress evidence of approximately ninety-four pounds of marijuana seized from one defendant's vehicle during a traffic stop, holding that the trial justice erred in granting Defendants' motions to suppress.Junjie Li was operating a vehicle and Zhong Kuang was in the passenger seat when a law enforcement officer initiated a traffic stop. While conversing with Li, the officer noticed Li began to exhibit nervous behavior and detected an order of marijuana coming from inside Kuang's vehicle. After a dog sniff, officers discovered marijuana. Li and Kuang moved, individually to suppress the marijuana. The trial justice granted the motions to suppress, holding that the extension of the traffic stop beyond its original scope was unreasonable because the officer did not have independent reasonable suspicion to prolong the stop. The Supreme Court vacated the superior court's orders, holding that the trial justice erred in concluding that the officer did not possess reasonable suspicion to prolong the stop based on the totality of the circumstances. View "State v. Li" on Justia Law