Justia Criminal Law Opinion Summaries

Articles Posted in Rhode Island Supreme Court
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After a jury trial, Defendant was convicted of six criminal counts relating to a shooting. Defendant appealed, arguing that, in denying his motion for a new trial, the trial justice overlooked and misconceived material evidence and failed to draw appropriate inferences from the evidence. Specifically, Defendant argued that the testimony of two key witnesses at trial was not credible. The Supreme Court affirmed, holding that nothing in the record showed the justice was either clearly wrong or that the justice overlooked or misconceived material and relevant evidence in his denial of Defendant’s motion for a new trial. View "State v. Silva" on Justia Law

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After a jury trial, Defendant was convicted of two counts of murder, and one count each of conspiracy and arson. The trial justice sentenced Defendant to three consecutive life sentences. The Supreme Court affirmed, holding (1) the admission of evidence of a robbery Defendant committed the day before the murders, even if error, was harmless beyond a reasonable doubt; (2) Defendant failed to preserve his objections to the content of the limiting instructions regarding the use of the robbery evidence; and (3) the trial justice did not abuse his discretion when he denied Defendant’s motion to pass the case. View "State v. Clements" on Justia Law

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In 1994, Defendant was charged with felony assault with a dangerous weapon (Count One) and willful or malicious injury to property (Count Two). Count One was dismissed in consideration of Defendant pleading nolo contendere to Count Two. In 2004, Defendant filed a motion to seal with respect to both counts. A justice of the superior court denied the motion. Defendant appealed the hearing justice’s denial of her motion with respect to Count One. The Supreme Court affirmed, holding that the hearing justice did not err when she denied Defendant’s motion to seal Count One pursuant to R.I. Gen. Laws 12-1-12.1(a) because Defendant had not been exonerated of all counts in the criminal case. View "State v. Diamante" on Justia Law

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After a jury trial, Defendant was convicted of two counts of first-degree child molestation sexual assault. Defendant appealed, contending, among other things, that the trial justice erred when it denied his motion to suppress statements made to police during a post-arrest interrogation. The Supreme Court (1) affirmed the trial justice’s denial of Defendant’s motion for a new trial and discerned no error arising from the justice’s evidentiary rulings; but (2) remanded the case to the superior court with directions to make additional findings of fact and credibility determinations concerning the voluntariness of Defendant’s confessions, as the trial justice failed to make the findings of fact and credibility determinations essential to support his ultimate finding of voluntariness. View "State v. Bojang" on Justia Law

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After a jury trial, Defendant was convicted of second-degree child molestation sexual assault. Defendant appealed, arguing that the trial justice erred when she allowed the State to elicit testimony from the complaining witness, which Defendant alleged violated Sup. Ct. R. Crim. P. 16 because the testimony was contrary to the State’s supplemental discovery responses. The Supreme Court affirmed the judgment of the superior court because the content of and the inconsistency among the complaining witness’s statements was disclosed to Defendant and was a proper subject for cross-examination. View "State v. Santiago" on Justia Law

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Defendant and the complaining witness (Complainant) lived together while Defendant maintained his own apartment. Due to certain incidents between Defendant and Complainant, Defendant was convicted after a jury trial of one count of simple domestic assault. Defendant appealed, arguing that the trial justice erred in denying his motion for acquittal and in denying his motion for a new trial because the evidence presented at trial did not establish that Defendant and Complainant were in a domestic relationship, as required under R.I. Gen. Laws 12-29-2. The Supreme Court affirmed the judgment of conviction, holding that the trial justice properly found Defendant and Complainant were in a domestic relationship. View "State v. Fleck" on Justia Law

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After a jury trial, Defendant was convicted of one count of first-degree child molestation and three counts of second-degree child molestation. On appeal, Defendant argued that the trial justice abused her discretion in refusing to exclude all evidence of uncharged acts of molestation and that the trial justice erred in denying Defendant’s motion for judgment of acquittal and Defendant's motion for a new trial. The Supreme Court affirmed, holding (1) Defendant’s first argument was not preserved for appeal; and (2) the trial justice did not err in denying Defendant’s motions for judgment of acquittal and a new trial. View "State v. Buchanan" on Justia Law

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Defendant pled nolo contendere to three counts of second-degree child molestation. Before he was sentenced, Defendant filed a motion to withdraw his plea. The trial justice denied the motion and sentenced Defendant to three concurrent sentences of fifteen years at the Adult Correctional Institutions. Eighteen months after sentencing, Defendant filed a motion to vacate judgment and sentence, arguing that his plea to the criminal charges should be set aside because his attorney did not inform him that the attorney was undergoing personal struggles during his representation of Defendant. The Supreme Court affirmed, holding (1) Defendant's appeal was not properly before the court; and (2) even if Defendant's argument was properly made, the argument was without merit. View "State v. Castriotta" on Justia Law

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In 1998, Applicant was convicted of first-degree murder and conspiracy to commit first-degree murder. Applicant later filed an application for postconviction relief on the basis of ineffective assistance of counsel. In connection with his application, Applicant filed a subpoena duces tecum seeking discovery of the mental health records of Appellant, who testified as an eyewitness in Applicant's murder trial. Appellant filed a motion to quash the subpoena. The superior court denied the motion. The Supreme Court vacated the order and remanded with directions to make further factual findings, holding that the trial justice erred in ordering the release of Appellant's health care records without first conducting the necessary statutory analysis. View "DePina v. State" on Justia Law

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After a jury trial, Defendant was convicted of assault with a dangerous weapon, carrying a pistol without a license, and using a firearm while committing a crime of violence. Defendant filed a motion for a new trial, arguing that the trial justice erred by accepting certain testimony. The trial justice denied Defendant's motion. Defendant appealed, contending that the trial justice overlooked and misconceived material evidence when denying his motion for a new trial. The Supreme Court affirmed, holding that the trial justice articulated adequate grounds for denying Defendant's motion and did not overlook or misconceive material evidence when making his decision. View "State v. Baker" on Justia Law