Justia Criminal Law Opinion Summaries
Articles Posted in Rhode Island Supreme Court
State v. Angeles
After a jury trial, Defendant was convicted of two counts of felony assault and one count each of possession of a controlled substance, resisting arrest, and reckless driving. Defendant petitioned the Supreme Court for a writ of certiorari, arguing that the trial justice’s instructions to the jury at the conclusion of the parties’ final arguments constituted reversible error because the instructions impermissibly commented on the evidence and were misleading and bolstering. The Supreme Court affirmed the judgment of the trial court, holding that the trial justice’s jury instructions were acceptable and that the trial justice did not comment on the evidence or, in any other way, confuse or mislead the jury. View "State v. Angeles" on Justia Law
Posted in:
Criminal Law, Rhode Island Supreme Court
Njie v. State
Defendant pled nolo contendere to one count of second-degree sexual assault and one count of intimidation of a witness in a criminal proceeding. Defendant filed an application for postconviction relief alleging that his sentence and conviction were unconstitutional due to the ineffective assistance of counsel. A hearing justice denied postconviction relief, concluding that Defendant made a knowing and intelligent plea at the time of his plea. The Supreme Court affirmed, holding (1) Defendant failed to provide the evidence required to support a claim of ineffective assistance of counsel; and (2) the justice who conducted the postconviction relief hearing did not overlook or misconceive material evidence in arriving at her findings. View "Njie v. State" on Justia Law
Bainum v. Coventry Police Department
Carel Bainum was found guilty of willful trespass because of her unwelcome contact with a former resident in the dementia ward of the Coventry Health and Rehabilitation Center. Bainum then brought a civil action against the Coventry Police Department, alleging that her willful trespass conviction was the consequence of two malicious acts by the Department. The motion justice granted summary judgment in favor of the Department. The Supreme Court affirmed, holding that summary judgment was proper because Plaintiff’s malicious prosecution claim failed as a matter of law, and therefore, her civil-conspiracy claim must also fail. View "Bainum v. Coventry Police Department" on Justia Law
State v. Nichols
After a jury trial, Defendant was convicted of two counts of first-degree murder, one count of felony assault, and three counts of discharging a firearm during a crime of violence. The trial justice sentenced Defendant to four consecutive life sentences followed by two consecutive twenty-year sentences. The Supreme Court affirmed, holding that the trial justice (1) did not err in admitting into evidence of a high-capacity magazine seized from Defendant’s home; (2) did not violate Rule 16 of the Superior Court Rules of Criminal Procedure when he admitted certain testimony; (3) did not err in dismissing a certain juror pursuant to the State’s peremptory challenge; and (4) articulated sufficient reasoning and did not overlook or misconceive any critical issue when he found that there was sufficient evidence to support a conviction of first-degree murder. View "State v. Nichols" on Justia Law
Posted in:
Criminal Law, Rhode Island Supreme Court
State v. Giard
Defendant pled nolo contendere to one count of felony assault and received a deferred sentence. Thereafter, Defendant was presented with a notice of violation based on an alleged act of second-degree child molestation of Jessica, Defendant’s niece. After a trial, the jury acquitted Defendant of second-degree child molestation. The hearing justice, however, imposed on Defendant a twenty-five-year sentence with five years to serve, concluding that, by his sexual contact with Jessica, Defendant had violated the conditions of his deferred sentence. The Supreme Court affirmed, holding that the hearing justice did not act unreasonably or arbitrarily in finding that a violation of the conditions of Defendant’s deferred sentence had occurred. View "State v. Giard" on Justia Law
Posted in:
Criminal Law, Rhode Island Supreme Court
State v. Muralles
After a jury trial, Defendant was found guilty of two counts of first-degree child molestation and two counts of second-degree child molestation. Defendant appealed, arguing that the trial justice erred in denying his motion for a new trial due to the purported lack of credibility on the part of the complaining witness and his half-brother and inconsistencies in their testimonies concerning the alleged molestations. The Supreme Court affirmed the superior court’s judgment of conviction, holding that the trial justice neither clearly erred nor overlooked or misconceived relevant evidence and that the trial justice properly denied Defendant’s motion for a new trial. View "State v. Muralles" on Justia Law
Posted in:
Criminal Law, Rhode Island Supreme Court
State v. Moore
After a jury trial, Defendant was convicted of first-degree murder, conspiracy to commit murder, and using a firearm when committing a crime of violence. The Supreme Court affirmed, holding that the trial justice did not err in (1) denying Defendant’s motion for a new trial on the grounds of inconsistencies in the witnesses’ testimonies; (2) refusing to give an “empty chair” jury instruction due to a witness’s absence of trial; and (3) making certain evidentiary rulings challenged by Defendant. Further, Defendant’s argument that the cumulative effect of the alleged errors warranted reversal was without merit. View "State v. Moore" on Justia Law
Posted in:
Criminal Law, Rhode Island Supreme Court
State v. Ciresi
Defendant was convicted of several criminal counts, including burglary and conspiracy to commit burglary. The aggregate sentences for all of Defendant’s convictions totaled thirty-five years. Defendant subsequently moved to reduce his sentence pursuant to Rule 35 of the Superior Court Rules of Criminal Procedure, arguing, inter alia, that he accepted responsibility for his actions and that his sentence violated the Eighth Amendment. The hearing justice denied Defendant’s motion to reduce sentence. On appeal, Defendant argued that his violated the Sixth Amendment and the Eighth Amendment. The Supreme Court affirmed, holding (1) the hearing justice was within his discretion to confirm Defendant’s punishment; (2) Defendant’s constitutional challenges were not cognizable in the context of a motion to correct an illegal sentence under Rule 35; and (3) even if Defendant could raise constitutional challenges under Rule 35, his arguments lacked merit. View "State v. Ciresi" on Justia Law
Duvere v. State
In 2009, Appellant entered a plea of nolo contendere to the offense of possession of between one to five kilograms of a controlled substance classified as marijuana, with knowledge and intent. In 2013, Appellant filed an application for postconviction relief seeking to vacate his 2009 nolo contendere plea, arguing that he neither knew nor understood the charges against him because a Haitian-Creole interpreter was not provided at his plea colloquy and that his trial counsel provided ineffective assistance. The hearing justice denied the postconviction-relief application. The Supreme Court affirmed, holding that the hearing justice did not err in finding that Appellant understood the plea colloquy. View "Duvere v. State" on Justia Law
Posted in:
Criminal Law, Rhode Island Supreme Court
State v. Lopez
After a jury trial, Defendant was convicted of murder in the first degree, discharging a firearm during a crime of violence, and conspiracy to commit murder. Defendant filed a motion for a new trial, arguing that the weight of the evidence did not support the verdicts in this case. The trial justice denied the motion. Thereafter, Defendant was sentenced to two mandatory consecutive sentences of life imprisonment for the murder and firearm convictions. The Supreme Judicial Court affirmed the judgments of convictions, holding that the trial justice did not overlook or misconceive material evidence or clearly err when he credited the testimony of Defendant’s co-conspirators. View "State v. Lopez" on Justia Law
Posted in:
Criminal Law, Rhode Island Supreme Court