Justia Criminal Law Opinion Summaries

The Supreme Court affirmed a superior court judgment of conviction for second-degree sexual assault following a 1993 jury trial and a 2019 superior court judgment adjudicating Defendant a probation violator for his failure to appear for execution of his sentence for that 1993 conviction, holding that there was no error.In 1993, a jury found Defendant guilty of one count of second-degree sexual assault and sentenced him to ten years' imprisonment. Defendant failed to appear for execution of his sentence, and a superior court clerk entered a judgment of conviction and commitment. In 2017, Defendant was arrested and extradited to Rhode Island. In 2018, a second trial justice ordered Defendant to begin serving the unsuspended portion of his original sentence. Thereafter, the State filed a notice of probation violation alleging that Defendant failed to comply with a probation condition when he failed to appear for execution of his sentence. The trial justice declared Defendant a violator of the terms of his probation and sentenced him to an additional three years' incarceration. The Supreme Court affirmed, holding that the trial justice did not err in adjudging Defendant a probation violator for his failure to appear for execution of his sentence. View "State v. Bienaime" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree child molestation sexual assault, holding that the trial justice did not err in denying Defendant's motion for a mistrial.On appeal, Defendant argued that the State posed a question to the complaining witness that was highly prejudicial and violated a pretrial order, and therefore, his motion for a mistrial was improperly denied. The Supreme Court affirmed, holding (1) there was nothing in the record to suggest that the jurors could have been so inflamed by the brief exchange such that they would be unable to examine the evidence in a calm and dispassionate manner; and (2) therefore, the superior court did not err in denying Defendant's motion for a mistrial. View "State v. Barboza" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of voluntary manslaughter, holding that there was no error in the proceedings below.On appeal, Defendant argued that the jury erroneously rejected his claim of self-defense when it returned a verdict of guilty of voluntary manslaughter. The Supreme Court affirmed, holding (1) in its role as fact-finder, the jury was free to reject Defendant's claim of self-defense; and (2) because this issue was never before the trial justice in the context of a motion for a new trial or a motion for judgment of acquittal, the trial justice did not weigh the evidence or pass upon the credibility of witnesses. View "State v. Stevens" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree murder, assault with intent to commit a felony, and two counts of discharging a firearm while committing a crime of violence, holding that there was no error in the proceedings below.Specifically, the Supreme Court held that the trial court did not err in (1) denying Defendant's motion to suppress evidence obtained from Defendant's cell phone, which police seized following his warrantless arrest; (2) denying Defendant's motion to discharge the jury impaneled on October 12, 2017 in violation of the Sixth Amendment; and (3) denying Defendant's motion to pass the case and for a mistrial. View "State v. Gonzalez" on Justia Law

The Supreme Court vacated the judgment of the superior court finding Defendant guilty of possession of child pornography and sentencing him to a suspended term of incarceration, with probation, and ordering him to meet special conditions of probation and to register as a sex offender, holding that there was no substantial basis for determining that probable cause existed in this case.On appeal, Defendant argued, among other things, that the superior court erred in denying his motion to suppress evidence that was seized from his home on the grounds that there was no probable cause to support the issuance of a search warrant. The Supreme Court agreed and vacated Defendant's convictions, holding that there was no substantial basis for determining that probable cause existed in this case based upon the language of the affidavit. View "State v. Resiner" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of first-degree child molestation sexual assault and two counts of second-degree child molestation sexual assault, holding that the trial justice did not err in excluding much of a defense witness's proposed testimony.On appeal, Defendant's sole contention was the trial trial justice erred by unfairly limiting the testimony of Jackelyn Rivera, the victim's aunt and a defense witness, in a violation of his constitutional right to present a full and fair defense. The Supreme Court affirmed, holding that, as to the portion of Jackelyn's testimony that would have constituted impermissible hearsay, the trial justice acted appropriately in excluding that testimony. View "State v. Rivera" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of second-degree murder and one count of discharging a firearm during a crime of violence, holding that the trial justice did not err in failing to grant a mistrial and properly denied Defendant's motion for a new trial.On appeal, Defendant argued that the trial justice erred by failing to declare a mistrial and in denying his motion for a new trial. The Supreme Court disagreed, holding (1) the trial justice did not err in failing to grant a mistrial because the grounds for a mistrial that Defendant raised were never articulated before the trial justice; and (2) the trial justice articulated adequate grounds for denying Defendant's motion for a new trial and did not overlook or misconceive material evidence. View "State v. Vidot" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of first-degree robbery and other firearm-related offenses, holding that there was no error in the proceedings below.On appeal, Defendant argued that the trial court erred in refusing to instruct the jury on cross-racial identification and that he was denied his right to due process when the trial court denied his motion to dismiss the State's habitual offender notice. The Supreme Court affirmed, holding (1) the trial justice did not err or abuse his discretion in failing to give Defendant's requested instruction regarding cross-racial identifications; and (2) the trial justice did not err in denying Defendant's motion to dismiss the State's habitual offender notice as untimely under R.I. Gen. Laws 12-19-21. View "State v. Hampton-Boyd" on Justia Law

The Supreme Court affirmed the judgment of the superior court dismissing Plaintiff's complaint against Defendants - Brown University and two of its officials - seeking damages and equitable relief arising out of Defendants' response to Plaintiff's sexual assault allegations, holding that the trial court did not err.Plaintiff brought his suit pursuant to the Rhode Island Civil Rights Act, chapter 112 of title 42 of the general laws (RICRA) and article 1, section 2 of the Rhode Island Constitution. The hearing justice granted Defendants' motion to dismiss for failure to state a claim, concluding that issue preclusion foreclosed the claims under RICRA based on a previous decision of the federal courts and that article 1, section 2 did not grant Plaintiff a private right of action. The Supreme Court affirmed, holding that the hearing justice did not err in dismissing Plaintiff's complaint. View "Doe v. Brown University" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of two counts of second-degree child molestation sexual assault, holding that the trial justice did not err.On appeal, Defendant argued that the trial justice erred by restricting Defendant's right of confrontation and sufficient cross-examination and erred by denying his motion for a new trial. The Supreme Court affirmed, holding (1) it was within the trial justice's discretion to exclude a certain line of questioning on a certain subject; (2) the trial justice did not err by excluding cross-examination with respect to a certain allegation; and (3) the trial justice did not err in denying Defendant's motion for a new trial. View "State v. Chadha" on Justia Law