Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgments of the superior court convicting Defendant following a jury trial for larceny of an automobile and adjudicating him a probation violator, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued, among other things, that the trial court erred in denying his motion to suppress certain evidence collected as a result of a warrantless search of his real-time cell-site location information (CSLI). The Supreme Court disagreed and affirmed, holding (1) the acquisition of real-time CSLI qualifies as a search under the Fourth Amendment for which a warrant is required; (2) any error in the trial justice's determination that the exigent circumstances exception to the warrant requirement applied to the facts of this case was harmless; (3) the trial justice did not abuse his discretion in denying Defendant's motion to exclude certain testimony, and any error in allowing other testimony to be admitted at trial was harmless; and (4) Defendant waived his last argument for appeal. View "State v. Sinapi" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of five counts of first-degree robbery and three counts of conspiracy to commit robbery, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued that the trial court erred in failing to exclude statements he made during a post-arrest police interview and in denying his motion for a new trial. The Supreme Court disagreed and affirmed, holding (1) the trial justice did not abuse his discretion by admitting Defendant's statements about firearms as probative of his opportunity, intent, preparation, or plan to supply a weapon for the robberies and conspire to commit the robberies; and (2) the prejudice arising from Defendant's "highly relevant" statements substantially outweighed their probative value. View "State v. Reverdes" on Justia Law

The Supreme Court affirmed the order of the superior court denying Defendant's motion to correct an illegal sentence, holding that there was no error on the part of the trial justice in denying Defendant's motion to correct his sentence.After a jury trial, Defendant was convicted of two counts of assault with a dangerous weapon in a dwelling house. As part of his sentence and as relevant to this appeal, Defendant received a ten-year nonparolable sentence enhancement as a habitual offender to be served consecutively to his first sentence. Defendant later filed a motion to correct an illegal sentence, arguing that his habitual offender sentence enhancement was illegal. The trial justice denied the motion. The Court of Appeals affirmed, holding that the trial justice correctly complied with the habitual offender statute. View "State v. Davis" on Justia Law

The Supreme Court affirmed the judgment of the superior court declaring Defendant to be in violation of the terms and conditions of his probation, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that there was a lack of sufficient evidence to support a finding that he had violated his probation and, alternatively, that the trial justice imposed an excessive sentence for the violation. The Supreme Court affirmed, holding that the trial justice (1) did not act arbitrarily or capriciously in concluding that Defendant had violated his probation; and (2) did not abuse his discretion sentencing Defendant to thirty-six months of his suspended sentences, two months to remain suspended. View "State v. Perkins" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of felony assault resulting in serious bodily injury and sentencing him to a term of twenty years at the Adult Correctional Institutions, holding that any error was harmless.On appeal, Defendant argued that the trial justice erred in admitting evidence that he struck an unrelated person in an unrelated event earlier on the evening in question, in violation of R.I. R. Evid. 404(b) and 403. The Supreme Court affirmed the conviction, holding (1) the admission of the challenged evidence was an abuse of discretion; but (2) the error did not contribute to the jury's evaluation of the evidence and Defendant's conviction and amounted to harmless error. View "State v. DeCosta" on Justia Law

The Supreme Court affirmed the judgment of the superior court in granting summary judgment in favor of Defendants, Rhode Island College and related individuals, on the grounds of qualified immunity, holding that Plaintiff was not entitled to relief on his claims of error.Plaintiff brought this action seeking equitable relief and damages under 42 U.S.C. 1983 and 1988 on the grounds that Defendants' conduct toward him during his Master of Social Work program violated his First and Fourteenth Rights. The superior court concluded that Defendants were entitled to qualified immunity and granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding that Plaintiff's arguments on appeal were unavailing. View "Felkner v. R.I. College" on Justia Law

The Supreme Court vacated the judgment of the superior court affirming the determination of the Rhode Island-Sex Offender Board of Review that Petitioner posed a level II, moderate risk of reoffense, holding that the trial justice erred in upholding the Board's classification of petitioner at a level II risk to reoffend.On appeal, Petitioner argued that the trial justice erred in finding that the State presented a prima facie case sufficient to justify the Board's determination that he posed a level II, moderate risk to reoffend. The Supreme Court agreed and vacated the judgment below, holding that the evidence presented by the State was insufficient to support the Board's moderate risk classification. View "State v. Decredico" on Justia Law

The Supreme Court affirmed the judgments of the superior court determining that the State proved by a preponderance of the evidence that Defendant had violated the terms and conditions of his probation, holding that the hearing justice did not act arbitrarily or capriciously in finding a violation.Defendant appealed from two judgments of probation violation entered in separate superior court cases stemming from the same adjudication, arguing that the hearing justice erred in finding that he had violated the terms and conditions of his probation in both cases. The Supreme Court upheld the judgments of probation violation, holding that the hearing justice did not err in finding by a preponderance of the evidence that Defendant had violated his probation. View "State v. Bliss" on Justia Law

The Supreme Court affirmed Defendant's murder convictions and sentences, holding that the trial justice's instructions adequately covered the law on all the crimes charged and that the trial justice did not err in denying Defendant's motions for judgment of acquittal and for a new trial.After a trial, the jury found that Defendant was guilty of first degree murder, to wit, felony murder during the course of an inherently dangerous felony and other crimes. On appeal, Defendant argued that the trial justice's jury instruction on robbery created reversible error, among other things. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial justice's jury instruction on robbery did not create reversible error; and (2) the trial justice did not err in denying Defendant's motion for judgment of acquittal and his motion for a new trial. View "State v. Gibson" on Justia Law

The Supreme Court affirmed the judgment of the trial court deciding to grant Defendant's request to represent himself and denying his motion for a new trial, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that his waiver of his right to the assistance of counsel was not valid and that the trial justice erred when she denied his motion for a new trial. The Supreme Judicial Court affirmed, holding (1) there was no error in the trial justice's decision allowing Defendant to discharge his attorney when and as he did; and (2) the record established that Defendant made a voluntary, knowing, and intelligent waiver of his right to the assistance of counsel; and (3) the trial justice did not err in denying Defendant's motion for a new trial. View "State v. Delossantos" on Justia Law