Justia Criminal Law Opinion Summaries

Articles Posted in Rhode Island Supreme Court
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After a jury trial, Defendant was convicted of six counts of first-degree sexual assault and three counts of second-degree sexual assault. The Supreme Court vacated count five of the judgment of conviction and affirmed the judgment of the superior court in all other respects, holding (1) the trial court did not err in declining to preclude certain testimony at trial under R.I. R. Evid. 404(b); and (2) although Defendant waived his appellate argument in this regard, the trial justice erred in denying Defendant’s motion for judgment of acquittal on count five of the indictment, and therefore, in the interest of justice and judicial economy, the judgment of conviction on count five is vacated. View "State v. Perez" on Justia Law

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Defendant was convicted of second-degree robbery and sentenced to twenty years with sixteen years to serve at the Adult Correctional Institutions and four years suspended with probation. Defendant filed a motion for a new trial. The trial justice denied the motion, finding that “there was more than sufficient evidence” to support the conviction. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not overlook or misconceive material evidence in denying Defendant’s motion for a new trial, nor did he commit clear error in denying Defendant’s motion for a new trial. View "State v. Pittman" on Justia Law

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The Supreme Court affirmed Defendant’s conviction for one count of domestic assault by strangulation and one count of simple assault. The court held that (1) the trial justice did not err in denying Defendant’s motion to pass the case after the prosecutor posed an allegedly prejudicial question to Defendant because the prosecutor’s question was not so inflammatory that the trial justice was unable to expiate the harm; and (2) the trial justice properly denied Defendant’s motion for judgment of acquittal on the grounds that Defendant was twice placed in jeopardy for the same act because Defendant was convicted of only one of the two counts at issue. View "State v. Funches" on Justia Law

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Appellant was found guilty of two counts of felony assault with a dangerous weapon, conspiracy to commit assault with a dangerous weapon, and other offenses. Appellant filed a pro se application for postconviction relief, arguing that he received ineffective assistance of trial counsel. The trial justice denied postconviction relief. On appeal, Appellant argued that deficiencies on the part of trial counsel prejudiced him in his trial and conviction. The Supreme Court affirmed, holding that Appellant failed to meet his burden of establishing ineffective assistance of counsel entitling him to postconviction relief. View "Chum v. State" on Justia Law

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The Supreme Court affirmed Defendant’s conviction on five counts of first-degree child molestation rendered after a jury trial. After denying Defendant’s motion for a new trial, the trial justice sentenced Defendant to five concurrent life sentences. The Supreme Court held (1) in dealing with Defendant’s motion for a new trial, the trial justice did not commit clear error or overlook or misconceive material and relevant evidence relating to a critical issue in the case; and (2) Defendant’s “constitutional right to present a full and fair defense” was not denied when the trial justice minimally limited Defendant’s cross-examination of two witnesses. View "State v. Ogoffa" on Justia Law

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The Supreme Court affirmed the superior court’s denial of Defendant’s motion for a new trial. The charges against Defendant arose from an incident involving Jessica Nunez and Defendant’s use of a knife on one date and a shooting on a subsequent date in which Theodora Nunez, Jessica’s mother, was injured. The Supreme Court affirmed the superior court’s denial of Defendant’s motion for a new trial, holding (1) the trial justice did not err in his analysis or conclusion in denying Defendant’s motion for a new trial; and (2) the trial justice did not commit clear error or overlook or misconceive material and relevant evidence in denying Defendant’s motion for a new trial. View "State v. Diaz" on Justia Law

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The Supreme Court vacated an order of the superior court denying the State’s request to adjudge Anthony Parrillo a probation violator based upon the hearing justice’s finding that Parrillo was no longer on probation at the time that he allegedly committed the offense of felony assault. The Court held (1) Parrillo was on probation and subject to being adjudged at the time he allegedly committed felony assault; (2) the hearing justice did not commit an error of law when he held that the doctrine of equitable estoppel did not bar the state from seeking to adjudge Parrillo a probation violator; and (3) the case must be remanded so that a hearing justice may address Parrillo’s due process argument in the first instance. View "State v. Parrillo" on Justia Law

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After a jury trial, Defendant was convicted of one count of first-degree sexual assault and four counts of second-degree child molestation sexual assault. The Supreme Court affirmed the judgments of conviction, holding that the superior court did not commit reversible error in (1) denying Defendant’s motion to pass the case after the State alluded to an “empty chair”; (2) failing to exclude the victim’s testimony that she had witnessed Defendant inappropriately touching another small child after the child not be located in order to corroborate the allegation; and (3) denying Defendant’s motion for judgment of acquittal on two counts in the indictment. View "State v. Cavanaugh" on Justia Law

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After a jury trial, Defendant was convicted on three separate counts of embezzlement and one count of conspiracy to commit embezzlement. Defendant filed a motion for a new trial, arguing that the evidence was not sufficient to prove his guilt beyond a reasonable doubt. The trial justice denied the motion. Defendant appealed, arguing that the trial justice erred in denying his motion for a new trial and in misconceiving the evidence, and in admitting certain evidence that Defendant alleged was irrelevant and unfairly prejudicial. The Supreme Court affirmed, holding (1) the trial justice conducted the appropriate analysis and was not clearly wrong in denying Defendant’s motion for a new trial; and (2) the trial justice was not clearly wrong in finding that the probative value of the evidence at issue outweighed its prejudicial effect. View "State v. McDonald" on Justia Law

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After a jury trial, Defendant was found guilty of three counts of child molestation against his stepdaughter. The Supreme Court affirmed the judgment of the superior court, holding (1) the trial justice did not abuse his discretion when he allowed the admission of evidence of other wrongful acts under R.I. R. Evid. 404(b); (2) the trial justice did not err when he allowed the State to introduce Donna Hogan as a witness where Hogan was not listed in the State’s response to discovery; (3) the trial justice did not err when he precluded defense counsel from cross-examining Donna Hogan about specific instances of conduct concerning the complaining witness’s character for untruthfulness; (4) the trial justice did not err when he allowed Hogan to testify as to the meaning of the complaining witness’s body language and demeanor; (5) the trial justice did not err when he denied Defendant’s motion for judgment of acquittal; and (6) the jury instructions were proper. View "State v. Thibedau" on Justia Law