Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was convicted of seven criminal offenses, including conspiracy to commit murder. The trial justice sentenced Defendant to consecutive life sentences plus twenty non-parolable years to run consecutively to the life sentences. The Supreme Court affirmed, holding (1) Defendant waived his arguments that the trial justice erred when he admitted certain evidence; and (2) the trial justice did not err by failing to dismiss the offense of discharging a firearm while in the commission of a crime of violence because, contrary to Defendant's assertions, the charge did not merge for double-jeopardy purposes with the offense of assault with a dangerous weapon with intent to murder. View "State v. Young" on Justia Law

After a jury trial, Defendant was convicted of multiple counts of felony assault and of using a firearm while committing a crime of violence and one count of carrying a pistol or revolver without a license. The Supreme Court affirmed on appeal, holding (1) the trial justice did not err in admitting a statement the victim made to police shortly after he was shot because the statement was relevant and the probative value of the evidence was not substantially outweighed by the danger of unfair prejudice; (2) the trial court did not deprive Defendant of his right to present a full defense, as Defendant was accorded leeway in presenting a third-party-perpetrator defense; and (3) the trial justice did not err in denying Defendant's motion for a new trial. View "State v. Covington" on Justia Law

After a bench trial, Defendant was convicted of criminal counts, including larceny, assault with a dangerous weapon, and violation of a protective order. Defendant appealed, arguing, among other things, that the State failed to comply with the Interstate Agreement on Detainers Act (IADA), and therefore, the trial court erred when it did not dismiss the charges against him. The Supreme Court affirmed the convictions, holding (1) the trial court did not err in denying Defendant's motion to dismiss, as Defendant forfeited his IADA argument for failing to raise it before the deadline expired; and (2) Defendant's convictions for both larceny and assault with a dangerous weapon did not violate the Double Jeopardy Clauses of the state and federal constitutions. View "State v. Oliver " on Justia Law

Defendant pled nolo contendere to assault with a dangerous weapon. The trial justice sentenced Defendant to twenty years incarceration, with ten years to serve and ten years suspended with probation. One year after Defendant unsuccessfully moved for a sentence reduction under R.I. R. Crim. P. 35, Defendant filed a motion requesting the trial justice assign for a hearing the previously filed Rule 35 motion. After a hearing, the trial justice granted the motion and amended Defendant's sentence to twenty years, nine years to serve and eleven years suspended with probation. The Supreme Court quashed the superior court's judgment modifying Defendant's term to serve, holding that Defendant's motion to reduce sentence/assign pursuant to Rule 35 was not properly before the trial court because, notwithstanding the language contained within the text of that motion, the filing was an untimely filed new motion, and therefore, the trial justice erred in granting the motion. View "State v. Keenan" on Justia Law

After a jury trial, Defendant was convicted of first degree sexual assault. The Supreme Court affirmed the conviction, holding that the trial court did not err in (1) declining to dismiss the indictment based upon a partially inaudible and incomplete grand jury record, as an unintentional failure to record or reproduce the grand jury proceedings does not affect the validity of the prosecution; (2) denying Defendant's motion to pass the case based upon Sup. Ct. R. Crim. P. 16 violations by the state, where a violation of Rule 16 occurred in this case, but the nondisclosures were not deliberate on the part of the prosecutor; and (3) admitting the testimony of an expert in the field of sexual abuse, as the testimony did not constitute impermissible vouching or bolstering of other fact witnesses. View "State v. Huffman" on Justia Law

Defendant was indicted for several sex-related crimes. Defendant opted to exercise his constitutional right to represent himself. After the jury was sworn, Defendant expressed his desire to absent himself from the trial in the event a plea agreement was not reached. The trial continued in Defendant's absence. The jury subsequently found Defendant guilty of three counts of first-degree child molestation sexual assault and two counts of first-degree sexual assault. Defendant appealed, contending, among other things, that the trial justice was constitutionally required to appoint counsel to represent him when he absented himself from trial. The Supreme Court affirmed, holding (1) Defendant validly waived his right to counsel; (2) the trial justice did not abuse his discretion in denying Defendant's post-waiver request for counsel; (3) the trial justice was not constitutionally required to appoint counsel to represent Defendant after he chose to proceed pro se and then absented himself from trial; and (4) Sup. Ct. R. Crim. P. 43 did not present any bar to Defendant's trial continuing, even after he elected not to be present. View "State v. Eddy" on Justia Law

Plaintiff was an inmate serving a life sentence incarcerated at the Adult Correction Institutions (ACI). Plaintiff filed an amended complaint naming as defendants employees of the ACI and Department of Corrections (DOC), alleging that Defendants violated his right to privacy by monitoring him via video camera while he was in his prison cell and that Defendants regularly harassed him. The trial justice dismissed the complaint. The Supreme Court affirmed. Meanwhile, Plaintiff filed another complaint against thirteen employees of the DOC. Along with the complaint, Plaintiff filed a motion to proceed in forma pauperis. The trial court denied Plaintiff's motion and entered an administrative order restricting Plaintiff from filing any further pro se actions in superior court. The Supreme Court vacated the orders restricting Plaintiff from filing any pro se actions, holding that the order did not comport with Supreme Court precedent and impermissibly infringed upon Plaintiff's right of access to the courts. View "Laurence v. R.I. Dep't of Corr." on Justia Law

After a trial at which he represented himself, Defendant was convicted of kidnapping, domestic felony assaults, intimidation of a witness, and violation of a no-contact order. The Supreme Court affirmed the convictions. Defendant subsequently filed several motions, which the superior court treated as a subsequent application for postconviction relief and then denied. In the motions, Defendant argued, inter alia, that the prosecutor erred in failing to produce certain victim-impact statements in response to his discovery requests. The Supreme Court affirmed, holding (1) even if the claims underlying this postconviction relief application were not barred by res judicata, they were meritless; (2) even if the State had disclosed the victim-impact statements to Defendant before trial, Defendant failed to demonstrate that the result of his trial would have been different, and therefore, Defendant's claim that the State violated Brady v. Maryland failed; (3) Defendant was not prejudiced by the State's failure to disclose the victim-impact statements under R.I. R. Evid. 16; and (4) Defendant was not entitled to postconviction relief based on newly discovered evidence. View "State v. Thornton" on Justia Law

After a jury trial, Defendant was convicted of simple domestic assault. The Supreme Court affirmed the judgment of conviction, holding that the trial justice (1) did not err in giving a jury instruction with respect to intent; (2) did not err in limiting Defendant's constitutional right to cross-examination of the complainant; (3) did not err in allowing a witness to express his opinion that Defendant was the aggressor because even if the testimony consisted of impermissible vouching, the admission of the testimony did not constitute prejudicial error; and (4) Defendant failed to establish any prejudice arising from the complainant's email having been read into the record rather than having been marked as an exhibit or otherwise provided to Defendant. View "State v. Kausel" on Justia Law

While on probation, Defendant fled from two police officers. After Defendant was arrested, a firearm was discovered on the floor of his car. A trial justice later found Defendant to be a violator of the terms and conditions of his probation. In addition to the probation-violation proceeding, the State charged Defendant with recklessly operating a motor vehicle, carrying a revolver without a license, and possession of a firearm after having been convicted of a crime of violence. During the course of the violation hearing, the State requested, in a motion in limine, that the trial justice interpret the Firearms Act in such a manner that a weapon need not be capable of expelling a projectile to fit within the definitions of "firearm" or "pistol." The trial justice denied the motion. The Supreme Court affirmed, holding (1) the trial justice did not err in finding that Defendant violated the terms of his probation; and (2) the trial justice correctly denied the State's motion in limine. View "State v. Hazard" on Justia Law