Justia Constitutional Law Opinion Summaries

Articles Posted in Rhode Island Supreme Court
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Defendant was convicted of violating his probation. The superior court executed thirty months of Defendant's previously imposed suspended sentence. The Supreme Court affirmed the judgment of the superior court, holding (1) Defendant waived his argument for appeal that the hearing justice properly refused to admit a letter written and sent to him by the State's complaining witness; (2) the hearing justice did not abuse its discretion in limiting testimony concerning past arguments between Defendant and the complaining witness about the complaining witness's drug use and whether the complaining witness had bought him drugs when he was in a drug-treatment program; and (3) the hearing justice did not act arbitrarily and capriciously in finding a violation. View "State v. Ford" on Justia Law

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Defendant was convicted of first-degree murder. The Supreme Court affirmed the conviction. Nearly a decade later, Defendant filed a pro se application for postconviction relief, claiming six allegations of error. The trial justice dismissed five out of the six allegations raised in the application as barred by principles of res judicata. A court-appointed attorney subsequently made an independent evaluation to determine whether Defendant's remaining claim of ineffective assistance of counsel had merit. Appointed counsel concluded that none of Defendant's arguments had merit. A trial justice then informed Defendant that his only allegation of ineffective assistance of counsel could proceed to a hearing and that he had no right to be represented by an attorney. After a hearing in which Defendant proceeded pro se, the trial justice granted the State's motion to dismiss. The Supreme Court vacated the judgment and remanded, holding (1) the trial justice erred in summarily dismissing five of Defendant's claims without first providing him with appointed counsel and a meaningful opportunity to respond; and (2) the trial justice's appointment of an "objective attorney" to make an "independent evaluation" of the merits of Defendant's claim of ineffective assistance of counsel violated R.I. Gen. Laws 10-9.1.5. View "Campbell v. State" on Justia Law

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Defendant was convicted of one count of first degree child molestation and two counts of second degree of child molestation. Defendant was the great-uncle of the complaining witness. On appeal, Defendant argued that the trial justice erred in failing to grant his motion for a new trial due to the lack of credibility of the witnesses and the inconsistent evidence concerning the alleged molestations. The Supreme Court affirmed, holding that the trial justice did not clearly err or misconceive evidence in denying Defendant's motion for a new trial, as the trial justice completed each of the analytical steps called for when a trial justice is presented with a motion for a new trial. View "State v. Gonzalez" on Justia Law

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Defendant was convicted of aiding and abetting murder and conspiracy to commit robbery. The Supreme Court affirmed on direct appeal. Defendant subsequently filed an application for postconviction relief, setting forth five allegations of error, including the allegation that counsel's failure to seek dismissal of the indictment on speedy trial grounds amounted to ineffective assistance of counsel. The trial justice denied the application. The Supreme Court affirmed, holding that the trial justice's denial of Defendant's allegation of ineffective assistance of counsel was correct, as Defendant's speedy-trial contention ultimately would have proven unsuccessful, and Defendant could not show that the result of the proceeding against him would have been different. View "Bido v. State" on Justia Law

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Defendant appealed from a superior court judgment of conviction declaring him to be in violation of his probation and executing four years of his previously imposed suspended sentence. On appeal, Defendant argued there was no reliable evidence for the hearing justice to find he violated the terms of his probation and therefore, the hearing justice acted arbitrarily and capriciously in finding a violation. The Supreme Court affirmed the judgment of the superior court, holding that the hearing justice was well within her discretion in concluding that Defendant violated the terms of his probation by not keeping the peace or being of good behavior. View "State v. Bellem " on Justia Law

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Appellant was convicted of first-degree murder, assault with intent to murder, and assault with a dangerous weapon. Appellant subsequently filed an application for postconviction relief, which the superior court denied. On appeal, Appellant contended (1) his postconviction relief application should have been granted based on a violation of his right to due process, and (2) he was prejudiced by the ineffective assistance of his trial counsel because his counsel failed to object to what Appellant maintained was improper witness vouching and because his trial counsel failed to object to a first-degree murder instruction that the trial justice imparted to the jury. The Supreme Court affirmed the denial of Appellant's application for postconviction relief, holding (1) Appellant's postconviction challenge was barred by the doctrine of res judicata, and Appellant's conviction was proper; and (2) trial counsel did not render ineffective assistance. View "Jaiman v. State" on Justia Law

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Defendant appealed from a judgment of conviction on two counts of assault with a dangerous weapon and one count of discharging a firearm while committing a crime of violence. Defendant argued on appeal that the trial justice erred when he (1) admitted into evidence a prejudicial hearsay statement as an excited utterance; and (2) admitted a statement as lay-witness opinion testimony. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not abuse his discretion when he (1) admitted into evidence the hearsay statement as an excited utterance; and (2) allowed a lay witness to testify as to what he perceived at the time of the alleged shooting. View "State v. Tep" on Justia Law

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After a jury trial, Defendant was found guilty of burglary, robbery in the first degree, and assault on a person over the age of sixty. The complainant, who was seventy-one years old at the time of trial, had suffered a stroke and couldn't remember "a lot of things" and also took prescription medication daily. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not err in (1) refusing to explicitly instruct the jury that, in assessing credibility, it could consider a witness's ability to observe and recall; (2) refusing to instruct the jury that a history of drug abuse may weaken the credibility of a testifying witness; and (3) denying Defendant's motion for a new trial, as "any reasonable jury would found Defendant guilty beyond a reasonable doubt." View "State v. Ricci" on Justia Law

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Defendant appealed from a superior court judgment of conviction for first-degree murder and three related crimes. On appeal, Defendant argued that the trial justice erred in denying his pretrial motions to suppress evidence and that the trial justice improperly denied his motions for a new trial and for a judgment of acquittal. The Supreme Court affirmed the judgment of the superior court, holding (1) the trial justice did not err in denying Defendant's motions to suppress; and (2) because the evidence was sufficient to support Defendant's convictions, the trial justice did not err when it denied Defendant's motions for a judgment of acquittal and for a new trial. View "State v. Musterd" on Justia Law

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Defendant appealed from a conviction of two felony counts of assault with a dangerous weapon and one count of discharging a firearm while committing a crime of violence. On appeal, Defendant argued (1) his statement to police should have been suppressed as the tainted fruit of an unlawful arrest; and (2) the trial justice deprived him of his right to confrontation by prohibiting defense counsel from cross-examining two police witnesses concerning his statements to police. The Supreme Court affirmed the judgment of conviction, holding, (1) the issue concerning the trial justice's denial of the motion to suppress was not a proper subject on appeal because at no point during Defendant's trial did the state introduce into evidence the statement he gave to the police, and moreover, Defendant's contention was without merit; and (2) Defendant did not properly preserve for the Court's review any challenge to the trial justice's limitations on his cross-examination, but nonetheless, the contention lacked merit. View "State v. Chum" on Justia Law