Justia Criminal Law Opinion Summaries

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

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

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

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

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

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

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

In 1990, Defendant pled nolo contendere to twenty-six offenses, including arson and a number of robberies. Defendant was sentenced to forty years' incarceration with twenty-eight years suspended, with probation, on the one arson and eight robbery charges. In 2011, a probation violation hearing was held based upon allegations of sexual assault. Thirteen witnesses testified during the hearing regarding the allegations. The superior court subsequently found Defendant to be in violation of the terms of his probation and sentenced him to serve the previously imposed suspended sentences. The Supreme Court affirmed, holding that the hearing justice's credibility findings were not arbitrary or capricious. View "State v. Raso" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree child molestation and five counts of second-degree child molestation. Defendant appealed, arguing, among other things, that the trial justice erred in admitting evidence that Defendant also allegedly molested the complainant's sister. The Supreme Court affirmed, holding (1) the trial justice did not abuse his discretion in admitting evidence of Defendant's other sexual misconduct; (2) the trial justice did not clearly err in denying Defendant's motion for a new trial; and (3) the trial justice correctly denied Defendant's request for new counsel prior to sentencing. View "State v. Mitchell" on Justia Law

After a jury trial, Defendant was convicted of kidnapping of a minor and reckless driving. Defendant appealed, arguing that the trial justice erred in admitting testimony about the alleged sexual assault of the kidnapping victim and in denying Defendant's motion for a new trial. The Supreme Court affirmed, holding (1) because the trial justice considered the potential effects of unfair prejudice and confusion of the issues and acted accordingly by issuing limiting instructions to the jury during the trial, the justice did not abuse her discretion in admitting the evidence of the sexual assault; and (2) the trial justice did not overlook or misconceive material evidence and was not otherwise clearly wrong in denying Defendant's motion for a new trial. View "State v. Clay" on Justia Law