Justia Criminal Law Opinion Summaries

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

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

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

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

After a jury trial, Defendant was found guilty of one count of assault with a dangerous weapon in a dwelling house and one count of breaking and entering of a dwelling house. The Supreme Court affirmed, holding (1) with respect to the breaking and entering count, the trial justice did not err in denying Defendant’s motion for a judgment of acquittal and his motion for a new trial because the State proved beyond a reasonable doubt that Defendant lacked consent to enter the house; and (2) the trial justice did not err in denying Defendant’s motion for a new trial on the assault with a dangerous weapon in a dwelling house count because the verdict was not against the weight of the evidence and the trial justice did not overlook or misconceive material evidence. View "State v. Grantley" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder, possessing a firearm after having previously been convicted of a violent crime, and other crimes. Defendant was sentenced to consecutive life sentences for first-degree murder and using a firearm during a violent crime. Defendant appealed, arguing that the trial justice erred in excluding the testimony of Stephen Bodden on the grounds that Bodden effectively invoked his Fifth Amendment privilege against self-incrimination. The Supreme Court affirmed, holding (1) Defendant’s appeal was not properly before the Court; and (2) nonetheless, the trial justice did not err when he ruled that Bodden properly invoked his Fifth Amendment privilege during the voir dire examination. View "State v. Barros" on Justia Law

After a jury-waived trial, Defendant was convicted of felony assault on a police officer, simple assault on a police officer, resisting arrest, driving under the influence of alcohol, and obstructing a police officer. During trial, the testimony each side presented diverged significantly, and the trial justice’s guilt assessment turned on his impression of witness credibility. The Supreme Court affirmed, holding that sufficient credible and competent evidence supported the trial justice’s guilt determinations on all counts beyond a reasonable doubt, and the trial justice did not overlook or misconceive any material evidence in reaching his decision. View "State v. Edwards" on Justia Law

In 1992, a jury found Defendant guilty of murder in the first degree. The Supreme Court affirmed the conviction. In 2004, Defendant filed an application for postconviction relief pursuant to Rhode Island’s Innocence Protection Act. For almost a decade, various orders were entered and discovery took place. In 2015, Defendant filed a second amended application for postconviction relief. The hearing justice granted Defendant’s application for postconviction relief and vacated his conviction, finding two Brady violations based on the State’s suppression of favorable evidence and a due process violation resulting from the police department’s unduly suggestive interviewing of witnesses. The Supreme Court affirmed the superior court’s judgment vacating Defendant’s conviction, holding that the hearing justice erred in vacating Defendant’s conviction on the basis of the former prosecutor’s failure to disclose pretrial statements of one of the State’s witnesses, and this claim of error was dispositive of the State’s appeal. View "Tempest v. State" on Justia Law

In 1996, Defendant entered a plea of nolo contendere to several sex offenses and was sentenced to a term of incarceration. After Defendant was released on probation, he applied for a transfer of his probation supervision from Rhode Island to Pennsylvania pursuant to the Interstate Compact for Adult Offender Supervision (ICAOS). Pennsylvania accepted the transfer request and imposed additional conditions of supervision upon Defendant. Defendant violated the additional conditions. As a result, the State of Rhode Island filed a notice of probation violation. The probation violation hearing justice adjudged Defendant to be a probation violator, determining that ICAOS rules mandated that he treat the violations to which Defendant admitted as a violation of his Rhode Island probation. The hearing justice then executed eight years of Defendant’s suspended sentence and imposed new conditions of probation. The Supreme Court affirmed in part and vacated in part, holding (1) the hearing justice did not act arbitrarily and capriciously in finding that Defendant violated the terms and conditions of his probation; (2) the hearing justice did not abuse his discretion in ordering Defendant to serve eight years of his suspended sentence; but (3) in imposing two additional conditions, the hearing justice plainly exceeded his statutory jurisdiction. View "State v. Brown" on Justia Law

After a jury trial, Defendant was convicted of assault with a dangerous weapon and vandalism. Defendant appealed, arguing that the trial justice erred in granting the State’s motion to preclude Defendant from discussing self-defense in his closing argument and by refusing to instruct the jury on the law of self-defense. The Supreme Court vacated Defendant’s conviction for felony assault with a dangerous weapon, holding (1) the trial justice erred by refusing to include a self-defense instruction in the jury charge; and (2) the holding with respect to the felony assault conviction does not affect Defendant’s conviction for vandalism. View "State v. Soler" on Justia Law