Justia Criminal Law Opinion Summaries

In 1998 after a plea hearing, the hearing justice accepted Amadeu Santos’s plea of nolo contendere to three counts of second-degree sexual assault. In 2012, Santos filed an application for postconviction relief, asserting that the 1998 plea colloquy did not comply with the Superior Court Rules of Criminal Procedure. The hearing justice denied Santos’s application, finding that it was barred by the doctrine of laches. The Supreme Court affirmed, holding that the hearing justice’s decision regarding the unreasonableness of Santos’s delay was not clearly wrong, nor did it constitute an abuse of discretion. View "Santos v. State" on Justia Law

After a jury trial, Defendant was convicted of possession with intent to deliver cocaine. Defendant appealed, arguing that the trial court erred by not excluding evidence that he was carrying cash at the time of his arrest and in denying him any remedy for the State’s late disclosure of that evidence. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not abuse its discretion in admitting the evidence, as the fact that Defendant had some amount of cash on his person at the time of the arrest was not unfairly prejudicial evidence. View "State v. Marte" on Justia Law

After a jury trial, Defendant was convicted of one count of voluntary manslaughter. Defendant appealed the trial justice’s denial of her motion for a new trial, arguing that the State failed to meet its burden of proving beyond a reasonable doubt that she did not act in self-defense when she killed the victim. The Supreme Court affirmed the superior court’s judgment of conviction, holding that the trial justice did not overlook or misconceive material and relevant evidence and was not otherwise clearly wrong in her denial of Defendant’s motion for a new trial. View "State v. Garrett" on Justia Law

After a jury trial, Defendant was convicted of carrying a pistol without a license and possession of a firearm by a person previously convicted of a crime of violence. The Supreme Court affirmed the judgment of conviction, holding (1) the trial justice did not err in denying Defendant’s motion for a judgment of acquittal because the the State produced sufficient evidence at trial from which a jury could infer beyond a reasonable doubt that Defendant possessed the handgun; and (2) the trial justice did not violate Defendant’s right to effective assistance of counsel by restricting defense counsel’s closing argument. View "State v. Ferrer" on Justia Law

Defendant was charged with two counts of first-degree robbery in connection with two armed robberies. Defendant filed several motions to suppress evidence obtained by police detectives following his arrest. A hearing justice granted Defendant’s motion to suppress certain evidence under the exclusionary rule to the Fourth Amendment to the United States Constitution because the evidence was gathered after an “illegal” extra-jurisdictional arrest. The Supreme Court vacated the order of the superior court, holding (1) the detectives’ actions in arresting Defendant outside their jurisdiction were in excess of their authority; but (2) the exclusionary rule of the Fourth Amendment did not mandate the suppression of the evidence obtained in this case. View "State v. Morris" on Justia Law

After a jury-waived trial, Defendant was convicted of one count of domestic felony assault and one count of domestic simple assault. On appeal, Defendant argued, among other things, that the trial justice erred in denying his motion to dismiss the criminal information, which contained the two counts on which Defendant was convicted. The Supreme Court affirmed, holding (1) the criminal information was sufficient to establish probable cause for the two counts for which Defendant was convicted; and (2) the trial justice did not commit any evidentiary errors during the course of the trial. View "State v. Ceppi" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first-degree child molestation sexual assault. Defendant subsequently moved for a new trial, asserting that the verdict failed to respond to the evidence and failed to do substantial justice between the parties. The trial justice denied Defendant’s motion for a new trial. On appeal, Defendant challenged only the trial justice’s denial of his motion for a new trial. The Supreme Court affirmed the judgment of conviction, holding that the trial justice did not overlook or misconceive the material evidence and conducted the proper analysis in denying Defendant’s motion. View "State v. Lake" on Justia Law

In 1990, Appellant was convicted of several criminal charges. Appellant was sentenced to thirty years’ imprisonment, with fifteen years to serve and fifteen years suspended. After Appellant was released from prison a justice of the superior court determined that Appellant had violated the terms and conditions of his probation and vacated the suspension of the remaining fifteen years of Appellant’s original sentence. One year later, Appellant filed an application for postconviction relief. An attorney was appointed to represent Appellant in his application but later filed a motion to withdraw, asserting that Appellant’s grounds for relief lacked merit. After a hearing, the attorney was allowed to withdraw. Appellant’s application for postconviction relief was ultimately denied. Appellant appealed, arguing that the hearing justice erred when she allowed Appellant’s attorney to withdraw. The Supreme Court affirmed, holding that the hearing justice was not clearly wrong and did not overlook or misconceive material evidence when she concluded that Appellant’s application lacked merit and granted Appellant’s attorney’s motion to withdraw. View "Roscoe v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder and sentenced to life imprisonment. Appellant filed a pro se application for postconviction relief alleging that he received ineffective assistance of counsel at trial. Appellant also filed a motion to appoint counsel. Counsel was appointed to investigate Appellant’s postconviction-relief claims in light of the Court’s holding in Shatney v. State. Counsel subsequently filed a Shatney report and requested that the court permit her to withdraw her appearance on Appellant’s claims of ineffective assistance of counsel. The trial court allowed counsel to withdraw from the case, and Appellant proceeded pro se on his postconviction relief claims. Following a hearing, the trial justice denied and dismissed Appellant’s application for postconviction relief. The Supreme Court vacated the judgment of the superior court, holding that the trial justice did not follow the appropriate procedure mandated by Shatney by not allowing Appellant an opportunity to be heard on the merits of his application before allowing the appointed attorney to withdraw. Remanded with directions to appoint counsel to Appellant in accordance with section R.I. Gen. Laws 10-9.1-5 for investigation and, if appropriate, litigation of Appellant’s allegations. View "Ramirez v. State" on Justia Law

After a jury trial, Defendant was convicted of assault with a dangerous weapon, using a firearm during a crime of violence, and carrying a firearm without a license. Defendants convictions arose out of a shooting inside the lobby of a hotel/nightclub. In 2011, Defendant requested a new trial based on allegedly newly discovered evidence that, sometime before trials, federal marshals had visited the apartment of one of the state’s witnesses. Defendant claimed that the visit from the marshals gave the witness a motive to falsely inculpate Defendant in the shooting. The trial justice denied Defendant’s request for a new trial, concluding that the information about the marshals did not constitute newly discovered evidence. The Supreme Court affirmed, holding that there was neither clear error nor a misconception of material evidence in the trial justice’s denial of Defendant’s motion for a new trial. View "State v. Quaweay" on Justia Law