Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the superior court declaring Defendant to be in violation of the terms and conditions of his probation, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that there was a lack of sufficient evidence to support a finding that he had violated his probation and, alternatively, that the trial justice imposed an excessive sentence for the violation. The Supreme Court affirmed, holding that the trial justice (1) did not act arbitrarily or capriciously in concluding that Defendant had violated his probation; and (2) did not abuse his discretion sentencing Defendant to thirty-six months of his suspended sentences, two months to remain suspended. View "State v. Perkins" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of felony assault resulting in serious bodily injury and sentencing him to a term of twenty years at the Adult Correctional Institutions, holding that any error was harmless.On appeal, Defendant argued that the trial justice erred in admitting evidence that he struck an unrelated person in an unrelated event earlier on the evening in question, in violation of R.I. R. Evid. 404(b) and 403. The Supreme Court affirmed the conviction, holding (1) the admission of the challenged evidence was an abuse of discretion; but (2) the error did not contribute to the jury's evaluation of the evidence and Defendant's conviction and amounted to harmless error. View "State v. DeCosta" on Justia Law

The Supreme Court affirmed the judgment of the superior court in granting summary judgment in favor of Defendants, Rhode Island College and related individuals, on the grounds of qualified immunity, holding that Plaintiff was not entitled to relief on his claims of error.Plaintiff brought this action seeking equitable relief and damages under 42 U.S.C. 1983 and 1988 on the grounds that Defendants' conduct toward him during his Master of Social Work program violated his First and Fourteenth Rights. The superior court concluded that Defendants were entitled to qualified immunity and granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding that Plaintiff's arguments on appeal were unavailing. View "Felkner v. R.I. College" on Justia Law

The Supreme Court vacated the judgment of the superior court affirming the determination of the Rhode Island-Sex Offender Board of Review that Petitioner posed a level II, moderate risk of reoffense, holding that the trial justice erred in upholding the Board's classification of petitioner at a level II risk to reoffend.On appeal, Petitioner argued that the trial justice erred in finding that the State presented a prima facie case sufficient to justify the Board's determination that he posed a level II, moderate risk to reoffend. The Supreme Court agreed and vacated the judgment below, holding that the evidence presented by the State was insufficient to support the Board's moderate risk classification. View "State v. Decredico" on Justia Law

The Supreme Court affirmed the judgments of the superior court determining that the State proved by a preponderance of the evidence that Defendant had violated the terms and conditions of his probation, holding that the hearing justice did not act arbitrarily or capriciously in finding a violation.Defendant appealed from two judgments of probation violation entered in separate superior court cases stemming from the same adjudication, arguing that the hearing justice erred in finding that he had violated the terms and conditions of his probation in both cases. The Supreme Court upheld the judgments of probation violation, holding that the hearing justice did not err in finding by a preponderance of the evidence that Defendant had violated his probation. View "State v. Bliss" on Justia Law

The Supreme Court affirmed Defendant's murder convictions and sentences, holding that the trial justice's instructions adequately covered the law on all the crimes charged and that the trial justice did not err in denying Defendant's motions for judgment of acquittal and for a new trial.After a trial, the jury found that Defendant was guilty of first degree murder, to wit, felony murder during the course of an inherently dangerous felony and other crimes. On appeal, Defendant argued that the trial justice's jury instruction on robbery created reversible error, among other things. The Supreme Court affirmed the judgment in its entirety, holding (1) the trial justice's jury instruction on robbery did not create reversible error; and (2) the trial justice did not err in denying Defendant's motion for judgment of acquittal and his motion for a new trial. View "State v. Gibson" on Justia Law

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