Justia Constitutional Law Opinion Summaries

In 2009, Defendant Ryan LaPlaca pled true to a probation violation. As a result, he was sentenced to two-and-one-half to five years in the state prison, with five years suspended. As a condition of his sentence, Defendant agreed to participate in a drug court sentencing program. Defendant waived his rights to any and all subsequent hearings as a condition of his participation in the program. Furthermore, any violation of the terms of the program would result in sanctions. The State moved to impose Defendant's suspended sentence when he pled true to the probation violation. The trial court granted the State's motion without an additional hearing, citing the conditions of Defendant's participation in the drug court program. On appeal, Defendant argued that the trial court erred by refusing to hold a hearing prior to issuing his sentence. On reversing the trial court's decision, the Supreme Court found that "it would subvert the requirements of due process to uphold the defendant's prospective waiver of his right to a hearing . . .[w]hen the defendant faces the potential imposition of a full sentence of incarceration." Accordingly, the Court remanded the case to the trial court for further proceedings.

Following a jury trial, Defendant Andre Rivera was convicted as an accomplice to reckless second-degree murder. In 2007, he and four others discussed robbing a local drug dealer. The group assailed the dealer, and when the dealer fought back, one of the five shot the dealer to death. Defendant appealed his conviction, arguing that the trial court erred in refusing to dismiss his indictment for lack of proof that he "acted with the purpose to promote or facilitate the specific actus reus of the principal offense" which was the murder of the drug dealer. Upon careful consideration of the trial court record, the Supreme Court found the evidence sufficient to support Defendant's conviction. The Court affirmed the trial court's decision.

Defendant Luis Lopez was convicted in 2007 on felony child endangerment charges. On appeal to the Supreme Court, Defendant argued that there was insufficient evidence presented at trial to convict him. The childâs mother found sexually suggestive images of her daughter on Defendantâs cell phone and called police. At issue on appeal was whether Defendant requested the child pose for him when the record revealed the child, when at play, liked to imagine herself as a runway model and "pose" for Defendant. The Supreme Court found that a "rational trier of fact" could have concluded that Defendant solicited the child for the suggestive images. The Court affirmed Defendantâs conviction.

Defendant James Mello appealed his conviction on four counts of delivering child pornography. On appeal to the Supreme Court, he argued that the Superior Court erred by denying his motion to suppress evidence derived from a search warrant issued by the district court which authorized a search for information held by his Internet service provider. On appeal to the Supreme Court, Defendant argued that the district court exceeded the scope of its jurisdiction by issuing the warrant. Furthermore, he argued that the warrant violated his state and federal constitutional rights. The Supreme Court found that the district court did not exceed its jurisdiction, and that Defendant had no expectation of privacy in the Internet information. Accordingly, the Court affirmed the trial court's decision.

In July 2009, a grand jury indicted Defendant Richard MacDonald on one count of aggravated felonious sexual assault for having sex with a person whom he knew to be âmentally defective.â At trial, Defendant filed a motion seeking in camera review of the victimâs medical and mental health records. The State did not object. The court received over two thousand pages of the victimâs medical records. The court assumed without review, that the records were probably relevant, and allowed the documents to be produced âfor Counselâs eyes only.â The State objected to the courtâs lack-of-review, arguing that the point of in camera review was for the court to decide which documents were appropriate. Defendant objected, and the State applied for a writ of certiorari to compel the trial court to determine the disclosure of the appropriate records. The Supreme Court granted the writ, and held that the lower courtâs failure to review the records was an error. The Court remanded the case to the trial court for an in camera review of the medical records.

Defendant Marilyn Demond-Surace appealed her conviction on two counts of vehicular assault. Defendantâs convictions stem from a 2005 motor vehicle accident that killed two people. The trial court granted Defendantâs motion to exclude all evidence related to blood alcohol tests because those tests were taken without Defendantâs consent, but denied Defendantâs motion to preclude the State from introducing evidence regarding her alcohol consumption. During the motion hearing the State said it did not have any witnesses that would testify to Defendantâs impairment. In ruling on the motions, the court said, âas far as the jury is going to know, [Defendant] was sober.â On appeal, Defendantâs arguments largely focused on the courtâs order to the State to âstay away from impairment.â Defendant argued that the trial court erred by failing to grant a mistrial for statements made by the State in its closing argument on the impairment issue. The Supreme Court found that â[i]n allowing evidence that the Defendant consumed alcohol despite having excluded all evidence that the Defendant was impaired by alcohol, the court made a distinction unsupported by our case law.â The Court reversed the lower court and remanded Defendantâs case for a new trial.

Defendant Todd Peters appealed his convictions on first-degree murder. On appeal, Defendant argued that the trial court erred when it denied his motions in limine to introduce evidence of alternative perpetrators, and to exclude phone record evidence at trial. On review of the lower courtâs record, the Supreme Court concluded that even if the trial court erred in these respects, the State met its burden of proving that these errors were harmless beyond a reasonable doubt. The Court affirmed the lower courtâs decision, and upheld Defendantâs convictions.

Defendant Michael Moncada appealed his conviction on three counts of aggravated felonious sexual assault, ten counts of felonious sexual assault and one count of bail jumping stemming from inappropriate contact he had with his girlfriendâs thirteen year-old daughter. Defendant argued on appeal that the trial court erred by finding him competent to stand trial, and that the evidence presented at trial was insufficient to convict him. The trial court heard testimony from two experts who both agreed that Defendant had âcertain cognitive defects.â But both did not agree whether Defendant was competent to stand trial. The State offered testimony of an ex-girlfriend of Defendant, who testified that she had seen Defendant reading the newspaper, and that he wrote her numerous letters when he served time in prison. Given all the evidence on the competency issue, the Supreme court found it âcannot conclude that no reasonable trier of fact could have found as the trial court did.â The Court affirmed the trial courtâs ruling on the competency issue, and also found that evidence presented at trial was sufficient to support his conviction.