Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of first-degree sexual assault and three counts of second-degree child molestation after a jury trial, holding that there was no error in the proceedings below.On appeal, Defendant argued that the trial justice clearly erred in denying his motion for a new trial because the justice overlooked and misconstrued material evidence and the weight of the evidence did not support the verdict. The Supreme Court disagreed and affirmed, holding that there was no reversible error in the trial justice's analysis of the motion for a new trial or in his decision denying the motion. View "State v. Acosta" on Justia Law

The Supreme Court affirmed the judgment of conviction and commitment entered in the superior court reflecting the fact that Defendant was found guilty of second-degree murder, holding that the trial justice did not err when she denied Defendant's motion to suppress.Before trial, Defendant filed a motion to videos located on a digital camera, arguing that the detectives who seized the camera improperly expended the scope of the judicially-approved warrant. The trial justice denied the motion. After a jury trial, Defendant was found guilty of second-degree murder and sentenced to life imprisonment. The Supreme Court affirmed, holding that the trial justice did not clearly err in denying the motion to suppress because, in seizing the camera, the police did not exceed the scope of the warrant. View "State v. Depina" on Justia Law

The Supreme Court affirmed Defendant's conviction for six counts of first-degree child molestation sexual assault, three counts of second-degree child molestation sexual assault, and second-degree child abuse, holding that there was no error in the proceedings below.On appeal, Defendant argued among other things, that the trial justice erred in admitting evidence of past bad acts without articulating the special relevance of the evidence in the limiting instructions. The Supreme Court disagreed, holding (1) the trial justice did not overlook or misconceive material evidence in denying Defendant's motion for a new trial; and (2) the trial justice did not err in admitting evidence under Rule 404(b) of the Rhode Island Rules of Evidence because Defendant's objection to the instructions he sought to argue was waived. View "State v. Phillips" on Justia Law

The Supreme Court vacated Defendant's conviction for assault and battery with a dangerous weapon, leaving the scene of an accident resulting in physical injury, reckless driving resulting in physical injury, and violating a no-contact order, holding that the trial justice erred in instructing the jury, resulting in reversible error.Defendant's conviction arose from a bar fight and its aftermath, when Defendant drove his vehicle into two women and then fled the scene. Three counts arose from violations of a no-contact order. On appeal, Defendant argued, among other things, that the trial justice committed reversible error when he instructed the jury that it was entitled to consider whether he was intoxicated at the time of the incident. The Supreme Court agreed and remanded the case for a new trial, holding (1) the trial justice erred when he instructed the jury that it could consider Defendant's intoxication, and the error required reversal of Defendant's convictions; and (2) the trial justice erred in ruling that two separate counts of violating a no-contact order did not merge. View "State v. Narcovich" on Justia Law

The Supreme Court vacated the judgment of the superior court convicting Defendant of possession of child pornography and sentencing him to a term of imprisonment of five years, with two years suspended, with probation, holding that the trial justice erred by denying Defendant an opportunity to address the jury with an opening statement.Defendant chose to proceed pro se at trial. Immediately after the State delivered its opening statement, Defendant also sought to offer an opening statement. Following a colloquy, the trial justice refused to allow Defendant to make an opening statement. The Supreme Court vacated the judgment below, holding that the trial justice erred when he did not make a proper inquiry of Defendant before precluding him from making an opening statement to the jury. View "State v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the superior court declaring Defendant to be a probation violator and sentencing Defendant to the nine years remaining on his suspended sentence, holding that there was no error or abuse of discretion.On appeal, Defendant argued that the order to serve the nine years remaining on his suspended sentence was improperly based on the new charges alone, without proper attention being given to the original conviction for which he was on probation. The Supreme Court affirmed, holding that the hearing justice acted within her discretion by executing the full nine years of Defendant's original suspended sentence. View "State v. Segrain" on Justia Law

The Supreme Court affirmed the judgment of the superior court finding Defendant guilty of assault with a dangerous weapon - a shod foot - and driving while intoxicated, holding that the trial justice did not err when she instructed the jury about the concept of aiding and abetting and that Defendant's Frye hearing was not conducted in error.On appeal, Defendant argued that the trial justice erred in charging the jury that it could convict him as either a principal or as an aider and abetter and that the trial justice erred during the Frye hearing because she failed to put him on notice that he was exposed to criminal liability for aiding and abetting. The Supreme Court affirmed, holding (1) an instruction on aiding and abetting was justified by the evidence; and (2) the trial justice did not err in the manner in which she proceeded during the Frye hearing. View "State v. Haffner" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of two counts of felony assault, holding that the trial justice did not abuse his discretion by permitting the state to impeach Defendant with a prior felony assault conviction.Defendant's first jury trial ended in a mistrial after a hung jury. After a second criminal jury trial before a different trial justice, the jury found Defendant guilty of two counts of assault with a dangerous weapon. On appeal, Defendant argued that the second trial justice abused his discretion by deviating from the law of the case doctrine and allowing a prior felony assault conviction to be introduced for impeachment purposes. The Supreme Court affirmed, holding that, under the circumstances, the trial justice did not abuse his discretion by allowing the State to impeach Defendant's credibility with his prior felony assault conviction. View "State v. Jones" on Justia Law

The Supreme Court affirmed the order of the superior court denying Defendant's motion for a new trial, holding that the motion for a new trial was untimely filed.Defendant was found guilty of sex trafficking of a minor and conspiring to do so and three counts of first-degree sexual assault. The Supreme Court vacated the convictions for sex trafficking of a minor and conspiring to do so and otherwise affirmed. Defendant subsequently filed a second motion for a new trial, arguing that the vacatur of his convictions on counts four and six constituted newly available evidence, allowing him to file this motion. The trial justice denied the motion. The Supreme Court affirmed, holding that the motion for a new trial was filed outside of the ten-day time limit set forth in Rule 33, which cannot be waived. View "State v. Maxie" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of eighteen counts of financial fraud crimes and sentencing him to a total of seven years to serve in prison, with the balance of the eighteen concurrent sentences suspended with probation, holding that the trial justice did not err or abuse her discretion.Specifically, the Supreme Court held (1) the trial justice did not abuse her discretion in admitting evidence related to Defendant's character; (2) the trial justice did not err by permitted a Rhode Island State Police detective to provide expert opinion testimony as a lay witness; (3) the trial justice was not clearly wrong in allowing a waiver of the attorney-client privilege; (4) the trial justice did not err when she denied Defendant’s motion to suppress evidence he claimed was illegally obtained by state action; (5) the trial justice did not err by denying Defendant's motion for a new trial; and (6) Defendant waived his remaining allegations of error. View "State v. Doyle" on Justia Law