Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was convicted of seven counts of simple assault. At the time of the alleged incidents, Defendant was a captain at the Rhode Island Adult Correctional Institutions (ACI). The charges leveled against Defendant related to his treatment of four ACI inmates. The Supreme Court affirmed the judgment of conviction, holding that the trial justice did not commit reversible error when he (1) denied Defendant's motion to sever his trial from that of his co-defendant; (2) granted the prosecution's motion to preclude the testimony of an inmate; (3) denied Defendant's motion for a new trial; (4) instructed the jury; and (5) allowed the prosecution to introduce certain photographs into evidence that were not disclosed during discovery, as the nondisclosure was inadvertent and did not prejudice Defendant. View "State v. Botas" on Justia Law

Defendant pled nolo contendere to breaking and entering. Over the next several years, the state filed five notices of probation violation against Defendant. The fourth notice of violation, the subject of this appeal, alleged that Defendant had violated R.I. Gen. Laws 11-8-2 by breaking and entering a residence. The sentencing magistrate revoked five years of Defendant's previous suspended sentence and retained eight years of that suspended sentence, with probation. Defendant subsequently filed a motion for modification or reduction of his sentence and a separate motion to vacate his sentence. A sentencing magistrate denied Defendant's motion. The Supreme Court granted in part and denied in part Defendant's appeal, holding (1) because Defendant had been released from prison, the issues that were raised about his admission of probation violation and the length of time that he was required to serve for violation of the conditions of his probation were moot; and (2) the sentencing magistrate erred when she calculated the time that remained on Defendant's suspended sentence and probation. Remanded. View "State v. Isom" on Justia Law

Defendants were charged with possessing marijuana with the intent to deliver it in violation of the Uniform Controlled Substances Act (CSA), manufacturing marijuana, and conspiracy to violate the CSA. Defendants moved to dismiss the criminal information as to all counts, relying on an affirmative defense and dismissal provision set forth in the Medical Marijuana Act. The superior court dismissed the criminal information, determining that Defendants lawfully possessed an authorized amount of marijuana plants and usable marijuana. The Supreme Court vacated the judgment of the superior court, holding that because, in contravention of the plain terms of the Act, no evidentiary hearing was held to show Defendants were in possession of an amount of medical marijuana that conformed to the limits set forth in the Act, the court's dismissal was premature. Remanded. View "State v. DeRobbio" on Justia Law

After a jury trial, Defendant was convicted of simple assault and disorderly conduct. The Supreme Court affirmed, holding that the superior court did not commit reversible error in refusing to (1) holding a posttrial evidentiary hearing to determine if the jury was racially biased or if certain juror misconduct had occurred; (2) permit the all fifteen jurors who heard the evidence to be seated on the deliberating panel, as no more than twelve jurors may be seated unless both parties agree; and (3) instruct the jury that aggressive actions of the police could constitute a defense to the charge of disorderly conduct. View "State v. Brown" on Justia Law

The director of the Department of Mental Health, Retardation and Hospitals (Department) petitioned the superior court for an emergency transfer of Irving Briggs, a sentenced inmate, from the forensic unit of the Eleanor Slater Hospital, where Briggs was receiving mental-health services, back to the Adult Correctional Institutions (ACI) where he had previously been incarcerated. The superior court allowed an emergency transfer in the absence of a full evidentiary hearing, finding that potential harm could occur to others if Briggs were to remain at the forensic unit. After a post-transfer evidentiary hearing, a mental health advocate filed a motion to impose sanctions, alleging that the Department contrived a materially inaccurate set of facts to secure an immediate discharge of Briggs from the hospital. The trial justice declined to find a conspiracy among the Department staff and administration to remove Briggs from the forensic unit at any and all costs. The Supreme Court affirmed, holding (1) the trial justice did not abuse his discretion when it denied to impose sanctions; and (2) Briggs's argument that his emergency transfer to the ACI violated his procedural due process rights was moot. View "In re Briggs" on Justia Law

After a jury trial, Defendant was convicted of several acts of child molestation and sexual assault. Defendant filed a motion for a new trial, which the trial justice denied. The Supreme Court affirmed the denial of Defendant's motion for a new trial, holding that the trial justice independently evaluated the evidence and assessed the credibility of the witnesses and did not overlook relevant and material evidence, thoroughly reviewed and summarized the testimony of the trial witnesses and issued a comprehensive decision setting forth his reasons for denying the motion for a new trial, and therefore correctly determined that credible evidence existed to support the jury's finding of guilt. View "State v. Paola" on Justia Law

In 2003, Defendant was charged with obtaining money under false pretenses. Defendant pled nolo contendere to the charge and agreed to pay restitution. Defendant's sentencing was deferred for a period of five years. In 2010, Defendant filed a motion to seal her records under R.I. Gen. Laws 12-19-19(c), arguing that under the plain language of the statute as amended in 2010, she was eligible to have her records sealed, and that if the court found that retroactivity was an issue, section 12-19-19(c) was entitled to retroactive application. The superior court denied the motion, finding that the statute was not intended to be applied retroactively. The Supreme Court affirmed, holding (1) the plaint language of section 12-19-19 as amended did not imply that the General Assembly intended for it to apply retroactively; and (2) declining to apply section 12-19-19(c) retroactively would not reach an absurd result. View "State v. Morrice" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree. The trial justice imposed a sentence of life imprisonment without the possibility of parole. Defendant appealed, contending that the trial justice committed reversible error in (1) admitting acts of prior misconduct he allegedly committed against the decedent, (2) denying his motion for a new trial, and (3) sentencing him. The Supreme Court affirmed, holding that the trial justice did not err in (1) admitting testimony relating to Defendant's acts of prior misconduct for the limited purpose of demonstrating Defendant's intent; (2) denying Defendant's motion for a new trial, as the evidence was sufficient to convicted him of first-degree murder; and (3) sentencing Defendant to life imprisonment without the possibility of parole, as any mitigating factors were far outweighed by the aggravating factors present in this case. View "State v. Martinez" on Justia Law

After a jury trial, Defendant was convicted of four counts of first-degree sexual assault. The trial justice sentenced Defendant to four concurrent sentences of twenty years incarceration, ten years to serve, ten years suspended with probation. Defendant subsequently filed a motion to reduce his sentence, which the trial justice denied. Because the appeal was not timely filed, Defendant sought review by the Supreme Court by means of a petition for a writ of certiorari. The Court granted the petition and affirmed the decision of the superior court, holding that Defendant did not establish that the trial justice abused his discretion when he denied the motion to reduce Defendant's sentence, as the sentence was neither beyond the power of the sentencing justice to impose, nor was it patently unjustified. View "State v. Lynch" on Justia Law

Defendant pleaded guilty to manslaughter in 1994 and received a sentence of thirty years in prison with twenty years suspended, along with twenty years probation. In 2011, the superior court adjudged Defendant to be in violation of his probation and executed seven years of his previously suspended sentence. Defendant appealed, contending that the evidence presented at the probation-violation hearing was insufficient to support the hearing justice's finding that Defendant violated the terms of his probation. The Supreme Court affirmed, concluding, as did the hearing justice, that the evidence adduced at the hearing was sufficient to support a finding that Defendant had violated the terms of his probation. View "State v. Lamoureux" on Justia Law