Justia Constitutional Law Opinion Summaries

Defendant pled nolo contendere to breaking and entering. Over the next several years, the state filed five notices of probation violation against Defendant. The fourth notice of violation, the subject of this appeal, alleged that Defendant had violated R.I. Gen. Laws 11-8-2 by breaking and entering a residence. The sentencing magistrate revoked five years of Defendant's previous suspended sentence and retained eight years of that suspended sentence, with probation. Defendant subsequently filed a motion for modification or reduction of his sentence and a separate motion to vacate his sentence. A sentencing magistrate denied Defendant's motion. The Supreme Court granted in part and denied in part Defendant's appeal, holding (1) because Defendant had been released from prison, the issues that were raised about his admission of probation violation and the length of time that he was required to serve for violation of the conditions of his probation were moot; and (2) the sentencing magistrate erred when she calculated the time that remained on Defendant's suspended sentence and probation. Remanded. View "State v. Isom" on Justia Law

After a jury trial, Defendant was convicted of simple assault and disorderly conduct. The Supreme Court affirmed, holding that the superior court did not commit reversible error in refusing to (1) holding a posttrial evidentiary hearing to determine if the jury was racially biased or if certain juror misconduct had occurred; (2) permit the all fifteen jurors who heard the evidence to be seated on the deliberating panel, as no more than twelve jurors may be seated unless both parties agree; and (3) instruct the jury that aggressive actions of the police could constitute a defense to the charge of disorderly conduct. View "State v. Brown" on Justia Law

After a jury trial, Defendant was convicted of several acts of child molestation and sexual assault. Defendant filed a motion for a new trial, which the trial justice denied. The Supreme Court affirmed the denial of Defendant's motion for a new trial, holding that the trial justice independently evaluated the evidence and assessed the credibility of the witnesses and did not overlook relevant and material evidence, thoroughly reviewed and summarized the testimony of the trial witnesses and issued a comprehensive decision setting forth his reasons for denying the motion for a new trial, and therefore correctly determined that credible evidence existed to support the jury's finding of guilt. View "State v. Paola" on Justia Law

In 2003, Defendant was charged with obtaining money under false pretenses. Defendant pled nolo contendere to the charge and agreed to pay restitution. Defendant's sentencing was deferred for a period of five years. In 2010, Defendant filed a motion to seal her records under R.I. Gen. Laws 12-19-19(c), arguing that under the plain language of the statute as amended in 2010, she was eligible to have her records sealed, and that if the court found that retroactivity was an issue, section 12-19-19(c) was entitled to retroactive application. The superior court denied the motion, finding that the statute was not intended to be applied retroactively. The Supreme Court affirmed, holding (1) the plaint language of section 12-19-19 as amended did not imply that the General Assembly intended for it to apply retroactively; and (2) declining to apply section 12-19-19(c) retroactively would not reach an absurd result. View "State v. Morrice" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree. The trial justice imposed a sentence of life imprisonment without the possibility of parole. Defendant appealed, contending that the trial justice committed reversible error in (1) admitting acts of prior misconduct he allegedly committed against the decedent, (2) denying his motion for a new trial, and (3) sentencing him. The Supreme Court affirmed, holding that the trial justice did not err in (1) admitting testimony relating to Defendant's acts of prior misconduct for the limited purpose of demonstrating Defendant's intent; (2) denying Defendant's motion for a new trial, as the evidence was sufficient to convicted him of first-degree murder; and (3) sentencing Defendant to life imprisonment without the possibility of parole, as any mitigating factors were far outweighed by the aggravating factors present in this case. View "State v. Martinez" on Justia Law

After a jury trial, Defendant was convicted of four counts of first-degree sexual assault. The trial justice sentenced Defendant to four concurrent sentences of twenty years incarceration, ten years to serve, ten years suspended with probation. Defendant subsequently filed a motion to reduce his sentence, which the trial justice denied. Because the appeal was not timely filed, Defendant sought review by the Supreme Court by means of a petition for a writ of certiorari. The Court granted the petition and affirmed the decision of the superior court, holding that Defendant did not establish that the trial justice abused his discretion when he denied the motion to reduce Defendant's sentence, as the sentence was neither beyond the power of the sentencing justice to impose, nor was it patently unjustified. View "State v. Lynch" on Justia Law

Defendant pleaded guilty to manslaughter in 1994 and received a sentence of thirty years in prison with twenty years suspended, along with twenty years probation. In 2011, the superior court adjudged Defendant to be in violation of his probation and executed seven years of his previously suspended sentence. Defendant appealed, contending that the evidence presented at the probation-violation hearing was insufficient to support the hearing justice's finding that Defendant violated the terms of his probation. The Supreme Court affirmed, concluding, as did the hearing justice, that the evidence adduced at the hearing was sufficient to support a finding that Defendant had violated the terms of his probation. View "State v. Lamoureux" on Justia Law

After a jury trial, Defendant was found guilty of two counts of second-degree child molestation. Defendant filed a motion for a new trial founded on a claim that he was deprived of pretrial access to certain relevant hospital records and police reports. The trial justice denied the motion after finding that none of the hospital records needed to have been disclosed to trial counsel and that the police reports were not discoverable. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not err in (1) denying Defendant's motion for a new trial; and (2) limiting Defendant's cross-examination of the complaining witness about her refusal to undergo a physical examination. View "State v. Burnham" on Justia Law

In 2003, after completing their respective deferred sentences, Defendants James Briggs and Anna Matthias unsuccessfully moved to expunge the records of their arrests and pleas. Briggs had pled nolo contendere to second-degree robbery, and Matthias had pled nolo contendere to possession of a controlled substance. After the General Assembly amended R.I. Gen. Laws 12-19-19 in 2010, Defendants filed motions to seal their records. The court denied the motions. The Supreme Court affirmed, holding (1) the plain language of section 12-19-19, as amended, does not demonstrate a legislative intent by necessary implication that the General Assembly intended the statute to apply to deferred sentences entered into before the 2010 amendments; and (2) the addition of subsection (c) to section 12-19-19 was a substantive amendment and thus not entitled to retroactive application. View "State v. Briggs" on Justia Law

Defendant was charged by information with threatening a public official with bodily harm as a result of the lawful performance of his official duties. The superior court dismissed the information for lack of probable cause, finding that, based on the contents of the information package, the state would not be able to prove beyond a reasonable doubt that Defendant's statements constituted a threat of bodily harm to a public official in the performance of his public duties. The Supreme Court affirmed, holding that there was no evidence in the record of probable cause to support the charge, and accordingly, the motion justice did not err in dismissing the information. View "State v. Baillargeron" on Justia Law