Justia Criminal Law Opinion Summaries

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

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

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

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

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

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

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

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

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

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