Justia Criminal Law Opinion Summaries
Articles Posted in 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
State v. Gibson
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
Posted in:
Criminal Law, Rhode Island Supreme Court
State v. Ditren
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
State v. Nickerson
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
Posted in:
Criminal Law, Rhode Island Supreme Court
State v. Whitfield
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