Justia Criminal Law Opinion Summaries

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

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