Justia Criminal Law Opinion Summaries
Articles Posted in Rhode Island Supreme Court
State v. Van Dongen
After a jury-waived trial, Defendant was convicted of domestic simple assault and domestic disorderly conduct. The Supreme Court affirmed the judgment, holding (1) sufficient competent and credible evidence existed in the record to support the trial justice’s finding beyond a reasonable doubt that Defendant committed the offenses; (2) the trial justice did not err in her credibility determinations and factual findings and applied the correct burden of proof with respect to Defendant’s claim of self-defense; (3) the trial justice did not abuse her discretion in her evidentiary rulings and or in limiting cross-examination; and (4) the trial justice did not overlook or misconceive material evidence in denying Defendant’s motion for a new trial. View "State v. Van Dongen" on Justia Law
Posted in:
Criminal Law, Rhode Island Supreme Court
Perry v. State
After a jury trial, Appellant was convicted of conspiracy to commit assault with a dangerous weapon and assault with a dangerous weapon. Appellant was also charged with first-degree murder, but the jury was unable to reach a verdict on that charge. After a second jury trial, Appellant was convicted of one count of first-degree murder. Appellant later filed an application for postconviction relief, arguing that his second trial was not fair because the justice who presided over that trial had previously represented Appellant in family court when Appellant was a minor. Appellant also alleged that his counsel at the second murder trial was ineffective. After a hearing, the hearing justice denied postconviction relief. The Supreme Court affirmed, holding (1) the hearing justice did not err in denying postconviction relief on the grounds that the trial justice at Appellant’s second murder trial should have recused; and (2) Appellant’s counsel did not provide ineffective assistance at Appellant’s second murder trial. View "Perry v. State" on Justia Law
State v. Roldan
After a jury trial, Defendant was convicted of felony assault with a dangerous weapon, discharging a firearm while committing a crime of violence, and carrying a handgun without a license. Defendant appealed, arguing primarily that the trial justice erred in denying his motion for a new trial because the testimony of the victim was not credible. The Supreme Court affirmed, holding (1) the trial justice did not clearly err or overlook or misconceive relevant and material evidence in concluding that the victim was a credible witness; and (2) any alleged shortcomings in the investigation in the aftermath of the shooting were harmless. View "State v. Roldan" on Justia Law
Posted in:
Criminal Law, Rhode Island Supreme Court
State v. Davis
After a jury trial, Defendant was found guilty of murder, using a firearm while committing a crime of violence resulting in a death, and carrying a pistol without a license. Defendant appealed, asserting a number of arguments. The Supreme Court affirmed the judgments of convictions, holding (1) the trial justice did not err when he declined to give a specific limiting instruction requested by Defendant to disregard a statement that the State gave during opening statements; (2) the trial justice did not abuse his discretion in denying Defendant’s request for “some sort of Neil v. Biggers identification instruction; (3) Defendant failed to preserve for appeal his argument that the trial justice admitted prejudicial evidence; and (4) the trial justice did not err when he denied Defendant’s motion for a new trial. View "State v. Davis" on Justia Law
Posted in:
Criminal Law, Rhode Island Supreme Court
State v. Offley
After a jury trial, Defendant was convicted of first-degree murder, conspiracy to commit murder, and related crimes. Defendant appealed, arguing that the trial justice erred in (1) admitting prior testimony of a witness at a coconspirator’s trial about Defendant’s level of intoxication on the night of the shooting; and (2) denying Defendant’s motion for a new trial on the grounds that the verdict was against the weight of the evidence. The Supreme Court affirmed, holding (1) any prior testimony that was admitted, by any means, regarding Defendant’s level of intoxication was immaterial to his defense, and Defendant did not suffer prejudice; and (2) the trial justice properly assessed the weight of the evidence and the credibility of the witnesses and articulated adequate reasons for denying Defendant’s motion. View "State v. Offley" on Justia Law
Posted in:
Criminal Law, Rhode Island Supreme Court
State v. Fry
After a jury trial, Defendant was found guilty of second degree murder. Defendant was sentenced to a term of forty years’ imprisonment. The Supreme Court affirmed, holding that the trial justice did not err in (1) instructing the jury concerning Defendant’s claim of accidental homicide; (2) allowing the State some flexibility to pose questions in yes-or-no form; (3) failing to declare a mistrial after the prosecutor discussed testimony with the State’s witness, a medical examiner, during breaks in the witness’s testimony; and (4) allowing admission of a seven-and-a-half minute video depicting the scene of the murder, including the victim’s body. View "State v. Fry" on Justia Law
Posted in:
Criminal Law, Rhode Island Supreme Court
State v. Lopez
After a jury trial, Defendant was convicted of assault with a dangerous weapon and other firearm-related offenses. Defendant appealed, arguing that the trial justice erred in denying his motion for a new trial because two key witnesses were not credible and the forensic evidence failed to conclusively link him to the shooting. The Supreme Court affirmed, holding that there was no basis for concluding that the trial justice committed clear error or that he overlooked or misconceived material evidence when he determined that the weight of the evidence supported the convictions and thus denied Defendant’s motion for a new trial. View "State v. Lopez" on Justia Law
Posted in:
Criminal Law, Rhode Island Supreme Court
Snell v. State
After a jury trial, Defendant was convicted of one count of felony domestic assault, two counts of assault with a dangerous weapon, and one count of simple domestic assault after previously having been convicted twice of domestic assault. The Supreme Court affirmed. Defendant later filed an application for postconviction relief, alleging that his trial counsel was ineffective because he stipulated to the fact that Defendant had two prior convictions for domestic violence in the presence of the jury. The Supreme Court affirmed, holding that trial counsel’s performance was not deficient, and even if Defendant were able to establish that his trial counsel was ineffective, Defendant’s right to a fair trial was not prejudiced by his trial counsel’s conduct. View "Snell v. State" on Justia Law
Roma v. Moreira
Plaintiff was injured when he fell down the stairs in his residence. Plaintiff filed a negligence action against Defendants, his landlords, alleging that Defendants failed to maintain the premises in a clean and safe condition. After a trial, the jury returned a verdict for Defendants. The superior court entered judgment in accordance with the verdict. Plaintiff appealed, arguing that the trial justice erred by denying his motion to pass the case due to jury prejudice. The Supreme Court affirmed, holding that the trial justice did not commit reversible error by rejecting Plaintiff’s motion to pass the case due to juror misconduct. View "Roma v. Moreira" on Justia Law
State v. Swiridowsky
After a jury trial, Defendant was found guilty of three counts of first degree sexual assault and one count of assault with the intent to commit a sexual assault. Defendant appealed, arguing that the trial justice erred in permitting the State to impeach him with a prior conviction for assault and denying his motion for a new trial. The Supreme Court affirmed, holding (1) the trial justice did not abuse his discretion in concluding that Defendant’s assault conviction was admissible to impeach Defendant’s credibility; and (2) the trial justice was neither clearly wrong nor misconceived or overlooked material evidence in denying Defendant’s motion for a new trial. View "State v. Swiridowsky" on Justia Law
Posted in:
Criminal Law, Rhode Island Supreme Court