Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the trial court deciding to grant Defendant's request to represent himself and denying his motion for a new trial, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that his waiver of his right to the assistance of counsel was not valid and that the trial justice erred when she denied his motion for a new trial. The Supreme Judicial Court affirmed, holding (1) there was no error in the trial justice's decision allowing Defendant to discharge his attorney when and as he did; and (2) the record established that Defendant made a voluntary, knowing, and intelligent waiver of his right to the assistance of counsel; and (3) the trial justice did not err in denying Defendant's motion for a new trial. View "State v. Delossantos" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of six counts of neglecting an adult with severe impairments and sentencing him to concurrent five-year sentences at the Adult Correctional Institutions, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) Defendant's argument that R.I. Gen. Laws 11-5-12 is vague and ambiguous because it does not notify a potential criminal defendant what conduct is proscribed was without merit; (2) section 11-5-12 does not require expert medical testimony to establish “severe impairment”; (3) the trial justice did not misapply the law when he denied Defendant’s motion for a new trial; and (4) Defendant's argument that the state violated Sup. Ct. R. Crim. P. 16 was without not properly preserved for appeal and was further without merit. View "State v. Vose" on Justia Law

The Supreme Court vacated the order of the superior court granting Defendant's motion to suppress two statements to Warwick police detectives in the course of their investigation, holding that the superior court abused its discretion.The trial justice suppress statements based on its findings that Defendant was in custody when he voluntarily accompanied the police detectives in an unmarked vehicle to search for evidence, that Defendant did not knowingly, intelligently, and voluntarily waive his Miranda rights, and that Defendant's video-recorded statement was inadmissible in accordance with Missouri v. Seibert, 542 U.S. 600 (2004). The Supreme Court vacated the superior court's order, holding (1) one of the statements at issue was admissible in evidence; and (2) remand was required for limited factual determination by the trial justice as to whether the other statement was a knowing, intelligent, and voluntary waiver of Defendant's Fifth Amendment rights. View "State v. Morillo" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting and committing Defendant for one count of second-degree murder and one count of first-degree child abuse, holding that there was no prejudicial error in this case.Specifically, the Supreme Court held that the trial justice (1) did not err in denying Defendant's motion to suppress the statement he made while at the police station after concluding that Defendant was not seized without probable cause prior to giving his statement; (2) did not err in denying Defendant's motion to dismiss all counts of the indictment as unconstitutionally vague; and (3) did not overlook or misconceive material evidence in denying Defendant's motion for new trial. View "State v. Jimenez" on Justia Law

The Supreme Court affirmed the judgments of the superior court finding Defendant to be in violation of the terms of his probation and sentencing him to serve portions of previously imposed suspended sentences, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that there was insufficient evidence to support a finding that he violated his probation on the basis that he failed to keep the peace and be of good behavior. The Supreme Court affirmed, holding that the hearing justice's findings were more than adequate to support a conclusion that Defendant violated his probation. View "State v. Kenner" on Justia Law

The Supreme Court affirmed the judgment of the superior court dismissing several counts of the criminal information against Defendants alleging accessing a computer system for fraudulent purposes and conspiracy, holding that the counts were properly dismissed.Defendant were charged with violations of R.I. Gen. Laws 11-52-2 and conspiracy. The trial judge granted Defendants' motions to dismiss for lack of probable cause, concluding that Defendants' conduct did not fall within the ambit of section 11-52-2, and therefore, Defendants could not be charged with conspiracy to violate section 11-52-2. The Supreme Court affirmed, holding that the trial justice did not err in granting the motions to dismiss. View "State v. Jilling" on Justia Law

The Supreme Court affirmed the order of the superior court granting Defendant's motion to suppress the statements he made to police at the scene of an automobile collision, holding that the superior court did not abuse its discretion in granting the suppression motion.Specifically, the Supreme Court held (1) the trial justice correctly determined that Defendant was in custody when he made incriminating statements to the law enforcement officer at the scene of the arrest and therefore correctly suppressed the statements Defendant made to the officers at the time; and (2) the state's second contention on appeal was not properly before the Court. View "State v. Corcoran" on Justia Law

The Supreme Court affirmed the order of the superior court granting Defendants' motion to dismiss all electronic, wire, or oral communications obtained through the use of wiretaps and any subsequently-obtained evidence in these consolidated cases, holding that the trial justice did not err.In granting Defendants' motion to suppress, the trial justice found that an associate justice of the superior court had no authority to issue the wiretap orders. The State appealed this ruling and argued, alternatively, that the trial justice erred in concluding that suppression of the evidence derived from the wiretap orders was warranted. The Supreme Court affirmed, holding that the trial court correctly concluded that the associate justice was not vested with the statutory authority to administer and sign the wiretap orders and, therefore, that those orders were in violation of R.I. Gen. Laws 12-5.1, the Interception of Wire and Oral Communications Act. View "State v. McGuire" on Justia Law

The Supreme Court vacated the decision and order of the superior court declaring Defendant to be in violation of his probation, holding that because Defendant was compliant with court-ordered restitution payments and ran out of time, the remedy could not include incarceration absent a finding of willful violation.Defendant pled nolo contendere to the charge of unlawful appropriation and was ordered to pay restitution. Defendant dutifully paid the amounts set forth in a periodic payment plan but, in anticipation of Defendant's failure to pay restitution in full prior to the expiration of his sentence, the state alleged that Defendant was in violation of his probation. An order subsequently entered declaring Defendant a probation violator. The Supreme Court vacated the decision below, holding that there were other remedies the state could pursue other than incarceration. View "State v. Regan" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree murder, first-degree robbery, and other crimes, holding that Defendant was not entitled to relief on her allegations of error.On appeal, Defendant argued that the trial justice erred in denying her motion to suppress the evidence found at her apartment, denying her motion to suppress the evidence found in her vehicle, and violating her right to confront a witness. The Supreme Court affirmed, holding (1) there was no error in the trial justice's denial of Defendant's motion to suppress the evidence obtained in the apartment based on insufficient probable cause; (2) the trial justice did not clearly err in denying Defendant's request for a Franks hearing; (3) the warrantless seizure of Defendant's vehicle did not violate her rights under either the State or Federal Constitution; and (4) Defendant's Confrontation Clause argument was waived. View "State v. Hudgen" on Justia Law