Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was found guilty of resisting arrest. Defendant appealed, arguing that the trial justice (1) abused his discretion by permitting the state to admit into evidence Defendant’s prior convictions; and (2) erred in permitting the prosecutor to reveal that two of Defendant’s prior assault convictions were upon police officers. The Supreme Court vacated the judgment of conviction, holding that the trial justice (1) was not clearly wrong in admitting the prior conviction evidence; but (2) erred in permitting the state to impeach Defendant’s testimony using his prior convictions of assault against police officers, and the error was not harmless. Remanded for a new trial. View "State v. Mercurio" on Justia Law

After a jury trial, Defendant was convicted of murder, assault with a dangerous weapon, and other crimes arising out of a shooting outside of a nightclub. The Supreme Court affirmed the judgment of conviction, holding (1) the trial justice did not err when he denied a motion to suppress out-of-court and in-court identifications, as the photographic array displayed to the witness was not unnecessarily suggestive; and (2) the trial justice did not err when he permitted the state to use peremptory challenges to African-American prospective jurors, as the challenges did not violate the Equal Protection Clause of the United States Constitution. View "State v. Gallop" on Justia Law

After a jury trial, Defendant was convicted of two counts of second-degree sexual assault. Defendant subsequently filed a motion for a new trial, arguing that testimony given by certain witnesses was contradictory, that the police department’s investigation of the incident was flawed, and that he was innocent. The trial justice ultimately denied Defendant’s motion. On appeal, Defendant challenged only the trial justice’s denial of his motion for a new trial. The Supreme Court affirmed the superior court’s judgment of conviction, holding that the trial justice in this credibility-intensive case was not clearly wrong, nor did he overlook or misconceive material and relevant evidence in denying Defendant’s motion for a new trial. View "State v. Barrios" on Justia Law

In 2007, Defendant entered a plea of nolo contendere to one count of possession of a controlled substance, for which he was sentenced to five years probation. In 2011, the superior court entered a judgment of conviction declaring Defendant to be in violation of the terms of his probation and sentencing Defendant to five years of his previously suspended sentence. Defendant appealed, arguing that the hearing justice acted arbitrarily and capriciously in finding that he violated the terms of his probation. The Supreme Court affirmed, holding that the hearing justice acted neither arbitrarily nor capriciously in finding that Defendant violated the terms and conditions of his probation. View "State v. Barrientos" on Justia Law

In 2009, three men attacked and robbed Complainant. Several days later, Complainant saw one of his attackers loitering on the street. After a foot chase, Complainant caught the attacker - Michael Long - and held him until the police arrived. Upon his arrest, Long implicated Defendant in the crime. After a jury trial, Defendant was convicted of one count of first-degree robbery. The Supreme Court affirmed the conviction, holding (1) Defendant waived his double jeopardy challenge; (2) the trial justice did not abuse her discretion by admitting Long’s prior police statement as a prior inconsistent statement, and the use of Long’s prior police statements as prior inconsistent statements did not violate the Confrontation Clause; (3) any use of leading questions posed to Long by the prosecutor was harmless; (4) the trial justice did not err by admitting Long’s statements to his former finacee in the presence of Defendant as adoptive admissions; and (5) the trial justice did not err by denying Defendant’s motion for a new trial. View "State v. Matthews" on Justia Law

Defendant was charged with ten offenses in a single indictment. After five of the counts were dismissed, the jury returned guilty verdicts on the five remaining counts of first-degree murder, first-degree robbery, and reckless driving, among other crimes. The trial justice sentenced Defendant to life for the murder conviction. The Supreme Court affirmed the judgments of conviction, holding that the trial justice (1) did not err when he did not grant Defendant’s motion to sever the counts relating to the murder/robbery from the counts relating to the police chase; (2) did not err by not granting Defendant’s motion to sever certain offenses committed on one date from offenses committed on another date; (3) did not violate Defendant’s right to a fair trial when he refused to allow a police artist’s sketch into evidence; (4) did not err when he denied Defendant’s motion to exclude three autopsy photographs from evidence; and (5) did not err in denying Defendant’s motion for a new trial. View "State v. Brown" on Justia Law

In the town of Tiverton, two police officers from the Little Compton police department had a discussion with Defendant about a motor-vehicle accident that occurred in Little Compton. The officers then transported Defendant in a police cruiser back to the scene of the accident, where they administered field-sobriety tests, which Defendant failed. Defendant was subsequently charged with driving under the influence of liquor or drugs, among other offenses. Defendant filed a motion to dismiss due to an unlawful arrest, arguing that the officers lacked the authority to arrest him in Tiverton. The trial judge concluded that the arrest was unlawful and dismissed the case. The Supreme Court quashed the judgment of the district court, holding that Defendant was not arrested by the Little Compton police while they were in Tiverton, and therefore, the trial judge erred when she granted Defendant’s motion to dismiss. Remanded. View "State ex rel. Town of Little Compton v. Simmons" on Justia Law

After a jury trial, Defendant was convicted of second-degree robbery and sentenced to a total of thirty years imprisonment. The Supreme Court affirmed, holding (1) the trial justice did not err in denying Defendant’s motion to sever the count charging a codefendant with carrying a handgun without a license, as Defendant did not show he suffered prejudice from the joinder of the charge to such a degree that he was denied a fair trial; and (2) the remainder of Defendant’s allegations of trial error were not preserved for appellate review. View "State v. Gadson" on Justia Law

In 1992, Appellant was incarcerated while awaiting the disposition of an allegation of first-degree child molestation. In 1994, Appellant pled nolo contendere to one count of first-degree child molestation. Appellant was sentenced to twenty years incarceration with twelve years suspended and twelve years probation. In 1997, Appellant was released from the Adult Correctional Institutions (ACI). Appellant completed his period of parole in 1999. In 2010, Appellant filed a petition for a writ of habeas corpus and applied for postconviction relief, arguing that his probationary period should have commenced and ended fifteen months earlier because his credit for time served caused him to be released from prison that much sooner. The superior court denied relief, concluding that Appellant’s sentence began in 1994 and ran until 2014. The Supreme Court affirmed, holding that the hearing justice did not miscalculate the length of Appellant’s sentence. View "Rose v. State" on Justia Law

Defendant was charged with one count of second-degree sexual assault. A jury trial commenced, but the trial justice granted Defendant’s motion for a mistrial due to a discovery violation. Thereafter, Defendant moved to dismiss the sexual-assault charge on double jeopardy grounds because of prosecutorial goading. The trial justice denied Defendant’s motion. The Supreme Court upheld the trial justice’s denial of Defendant’s motion to dismiss the charge, holding that sufficient evidence in the record supported the trial justice’s finding that the objective facts did not give rise to an inference of intentional goading. View " State v. Rolle" on Justia Law