Justia Criminal Law Opinion Summaries

Articles Posted in Rhode Island Supreme Court
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Defendant was adjudicated by a justice of the superior court to be in violation of the terms and conditions of his probation for his participation in a home invasion. Defendant appealed, arguing that the trial justice acted arbitrarily and capriciously in finding him to be a probation violator. The Supreme Court entered an order directing the parties to appear and show cause why the issues raised in this appeal should not be summarily decided. The Court then determined that cause had not been shown and affirmed, holding that the trial justice did not act arbitrarily or capriciously in finding that Defendant violated the terms of his probation. View "State v. Gibson" on Justia Law

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A criminal complaint was filed against Defendant charging him with burglary. After a combined bail and violation hearing, a hearing justice found that Defendant failed to be of good behavior and that Defendant violated the terms of his violation. Defendant appealed, arguing, inter alia, that evidence obtained from the search of a vehicle should have been suppressed because it was obtained from an illegal search and seizure. The Supreme Court affirmed, holding (1) Defendant lacked standing to contest the legality of the search of the vehicle; (2) even assuming the police illegally obtained the evidence, the exclusionary rule did not apply at Defendant’s probation revocation hearing; and (3) the hearing justice did not act arbitrarily or capriciously in finding that Defendant violated his probation. View "State v. Ditren" on Justia Law

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After a jury trial, Defendant was convicted of four counts of first-degree sexual assault and one count of felony assault and battery for his brutal attack of a sixteen-year-old girl. Two years after the attack, law enforcement performed a buccal swab on Defendant, which matched the profile developed from a sample taken from the victim’s underwear. As a result, Defendant was indicted on seven felony counts. The Supreme Court affirmed the judgment, holding (1) the trial justice did not err in denying Defendant’s motion for judgment of acquittal based on the sufficiency of the evidence and Defendant’s motion for a new trial based on alleged errors occurring at trial; and (2) the trial justice did not err in denying Defendant’s motion to exclude the testimony of a forensic evidence analyst who testified at trial. View "State v. Nickerson" on Justia Law

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After a jury trial, Defendant was convicted of two counts of assault with a dangerous weapon and one count of simple assault. On appeal, Defendant argued, among other things, that the prosecutor improperly vouched for the credibility of two witnesses during her closing argument. The Supreme Court affirmed the convictions, holding (1) the trial justice did not abuse his discretion by allowing the state to impeach Defendant’s credibility with his fourteen prior criminal convictions; and (2) although a portion of the prosecutor’s closing argument was akin to vouching, the trial justice did not err by refusing to pass the case. View "State v. Whitfield" on Justia Law

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After a jury trial, Defendant was found guilty of two counts of second-degree child molestation sexual assault. The Supreme Court affirmed the superior court’s judgment of conviction and its denial of Defendant’s motion for a new trial, holding (1) the trial justice did not abuse his discretion in denying Defendant’s motion to pass the case after the prosecutor engaged in an improper line of questioning to a witness, as any prejudice which may have resulted was cured by the trial justice’s instruction to the jury; and (2) the trial justice did not misconceive or overlook material testimony and did not otherwise commit clear error in denying Defendant’s motion for a new trial. View "State v. Hie" on Justia Law

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In 1990, Applicant was convicted of one count of first-degree sexual assault. In 2001, Applicant filed a pro se application for postconviction relief, alleging ineffective assistance of counsel and trial error. In 2005, the hearing justice denied the application. The Supreme Court affirmed, holding that the hearing justice properly did not commit clear error or misconceive material evidence in rendering his decision, as (1) Applicant’s claims relating to alleged errors committed by the trial justice were barred by the doctrine of res judicata; and (2) Applicant failed to show to his trial counsel’s representation fell below an objective standard of reasonableness. View "Lamoureux v. State" on Justia Law

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After a jury trial, Appellant was convicted of two counts of first-degree child molestation and one count of second-degree child molestation. The Supreme Court affirmed the convictions on direct appeal. Appellant subsequently filed an application for postconviction relief, arguing that his trial counsel provided ineffective assistance. The trial justice denied the application, concluding that Appellant failed to establish that his counsel’s performance was deficient. The Supreme Court affirmed, holding that the trial justice did not err in finding that trial counsel performed at a high level and in thus denying Appellant’s application for postconviction relief. View "Merida v. State" on Justia Law

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Defendant was charged with several crimes in connection with a drive-by shooting. After a jury trial, Defendant was convicted of carrying a firearm in a motor vehicle without a license and attempting to elude a police officer. Defendant filed a motion for a new trial with respect to both convictions. The trial justice granted the motion on the charge of attempting to elude a police officer but denied the motion with respect to the firearm charge. The Supreme Court affirmed the superior court’s judgment of conviction, holding that the trial justice did not err in denying Defendant’s motion for a new trial with respect to the charge of carrying a firearm in a motor vehicle without a license. View "State v. Nabe" on Justia Law

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After a jury trial, Defendant was found guilty of six counts of first-degree sexual assault and four counts of second-degree sexual assault stemming from his unlawful conduct with his girlfriend’s daughter. Defendant was sentenced to fifty years, with twenty-five years suspended, with probation. The Supreme Court affirmed, holding that the trial justice (1) did not err in admitting evidence concerning prior acts of misconduct committed by Defendant against the complainant, including “play fighting” evidence and corporal punishment evidence; (2) did not err by allowing an examining physician to testify to statements made by the complainant during the course of her treatment; and (3) did not err by denying Defendant’s motion for a new trial. View "State v. Watkins" on Justia Law

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Defendant was charged with several counts of first-degree child molestation and second-degree child molestation stemming from Defendant's unlawful conduct with the niece of his girlfriend. The case proceeded to trial. During the redirect-examination of the complaining witness, the trial justice admitted into evidence some nonspecific testimony about previous, uncharged acts of sexual misconduct. The jury eventually convicted Defendant of two counts of first-degree child molestation and three counts of second-degree child molestation. Defendant appealed, challenging the trial justice’s admission of the testimony about prior bad acts. The Supreme Court affirmed, holding that the trial justice did not abuse her discretion when she permitted the complaining witness to testify about other nonspecific evidence of prior bad acts. View "State v. Acevedo" on Justia Law