Articles Posted in Rhode Island Supreme Court

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of first-degree child molestation sexual assault and one count of the sale or distribution of photographs of a minor suggesting that the minor engaged in, or is about to engage in, a sexual act. On appeal, Defendant argued that the trial court violated his Sixth Amendment right to cross-examine the complaining witness regarding her allegations against her biological father. The Supreme Court disagreed, holding that the trial justice did not abuse his discretion in precluding the admission of this evidence. View "State v. Danis" on Justia Law

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The Supreme Court vacated the decision of the superior court granting Defendant’s motion to suppress statements he made to a Massachusetts Department of Children and Families investigator on grounds that the investigator’s failure to advise Defendant of his right to counsel rendered the statements involuntary. Defendant was indicted by a grand jury on four counts of child molestation. The Supreme Court vacated the decision of the hearing justice granting Defendant’s motion to suppress, holding that, under the circumstances of this case, Defendant’s statements were voluntary, and the motion to suppress should have been denied. View "State v. Gouin" on Justia Law

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The Supreme Court affirmed the judgment of the superior court denying Petitioner’s application for postconviction relief, in which Petitioner claimed that he received ineffective assistance of trial counsel. The Court held (1) Petitioner’s trial counsel was not ineffective for failing to utilize an expert witness on false confessions; (2) the trial justice did not clearly err in refusing to approve funding for the hiring of an expert witness on false confessions in this postconviction relief action; and (3) trial counsel was not ineffective for failing to file a motion to recuse the justice during the trial, and the trial justice did not err in not recusing himself from hearing the instant application for postconviction relief. View "Barros v. State" on Justia Law

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The Supreme Court affirmed the order of the superior court dismissing Plaintiff’s complaint for declaratory relief asserting that he had a right to access to records in the possession of the Rhode Island Department of Elementary and Secondary Education (RIDE) pursuant to the Access to Public Records Act (APRA). The motion justice found that the requested documents were not public records subject to disclosure under APRA. The Supreme Court agreed, holding that the records requested by Plaintiff were not public records for the purposes of APRA, and therefore, the motion justice properly disposed of Plaintiff’s complaint on RIDE’s motion to dismiss. View "Pontarelli v. R.I. Department of Elementary & Secondary Education" on Justia Law

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The Supreme Court affirmed the judgment of the superior court granting the City of Providence’s motion for summary judgment in this lawsuit filed by Lehigh Cement Co. seeking to recover approximately $500,000 in real estate taxes billed and collected by the city from 2006 to 2009. The court held (1) the hearing justice did not err in granting summary judgment on Lehigh’s claim under R.I. Gen. Laws 44-5-23, as the statute does not provide relief to a taxpayer; (2) summary judgment on Lehigh’s claim under the fair distribution clause of the Rhode Island Constitution was appropriate; and (3) the hearing justice did not err in granting summary judgment on Lehigh’s claim under R.I. Gen. Laws 44-5-27. View "Lehigh Cement Co. v. Quinn" on Justia Law

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The Supreme Court vacated the judgments of conviction entered in the superior court following a jury trial convicting Defendant of three counts of assault with a dangerous weapon and one count of carrying a pistol without a license. The Supreme Court held (1) the superior court justice erred in denying Defendant’s motion to suppress evidence seized by police during a warrantless search of Defendant’s home because the state failed to overcome the presumption of unreasonableness that accompanies every warrantless entry into a home; and (2) the admission of the unlawfully seized evidence was not harmless beyond a reasonable doubt. View "State v. Terzian" on Justia Law

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Defendant was charged via a criminal information with breaking and entering a dwelling. After a trial, the trial justice granted Defendant’s motion to pass the case based on based on a comment made by the prosecutor during closing argument. Thereafter, Defendant filed a motion to dismiss the information on grounds of double jeopardy. The trial justice denied Defendant’s motion to dismiss, ruling that the State’s actions were not intended to goad Defendant into seeking a mistrial. The Supreme Court affirmed, holding that the trial justice did not err in determining that the prosecutor did not intentionally goad Defendant into moving for a mistrial. View "State v. Corleto" on Justia Law

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Defendant pleaded nolo contendere to assault in a dwelling house with intent to murder while armed with a dangerous weapon and carrying a pistol on or about his person without a license. While Defendant was on parole, he was arrested and charged with domestic assault and failure to relinquish a telephone. Also while on parole Defendant was charged with breaking and entering. After a hearing, Defendant admitted that he violated the terms and conditions of his probation. Defendant later filed an application for postconviction relief alleging that he was denied the effective assistance of counsel at the probation violation hearing and that he did not knowingly, intelligently, and voluntarily admit a violation of probation. A hearing justice denied Defendant’s application for postconviction relief. The Supreme Court affirmed, holding (1) any alleged deficient performance by Defendant’s attorney was not so prejudicial as to deprive Defendant to a fair trial; and (2) Defendant’s admission was made knowingly, intelligently, and voluntarily. View "Gomes v. State" on Justia Law

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The Supreme Court affirmed Defendant’s conviction on five counts of first-degree child molestation rendered after a jury trial. After denying Defendant’s motion for a new trial, the trial justice sentenced Defendant to five concurrent life sentences. The Supreme Court held (1) in dealing with Defendant’s motion for a new trial, the trial justice did not commit clear error or overlook or misconceive material and relevant evidence relating to a critical issue in the case; and (2) Defendant’s “constitutional right to present a full and fair defense” was not denied when the trial justice minimally limited Defendant’s cross-examination of two witnesses. View "State v. Ogoffa" on Justia Law

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Defendant pled nolo contendere to one count of second-degree sexual assault and one count of intimidation of a witness in a criminal proceeding. Defendant filed an application for postconviction relief alleging that his sentence and conviction were unconstitutional due to the ineffective assistance of counsel. A hearing justice denied postconviction relief, concluding that Defendant made a knowing and intelligent plea at the time of his plea. The Supreme Court affirmed, holding (1) Defendant failed to provide the evidence required to support a claim of ineffective assistance of counsel; and (2) the justice who conducted the postconviction relief hearing did not overlook or misconceive material evidence in arriving at her findings. View "Njie v. State" on Justia Law