Justia Constitutional Law Opinion Summaries

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

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

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

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

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

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

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

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

After a consolidated trial, a Providence County Superior Court jury found Defendant John Kluth guilty of thirty counts of obtaining money by false pretenses. Thereafter, the trial justice sentenced Defendant to a total of thirty-five years, with sixteen years to serve at the Adult Correctional Institutions and the remainder suspended, with probation. On appeal, he contended: (1) that the then presiding justice of the Superior Court exceeded his authority in granting the prosecutor's request to change venue; (2) that the charges filed against him were improperly joined as a matter of law, in view of the provisions of Rule 8(a) of the Superior Court Rules of Criminal Procedure; and (3) that, even if the charges had been properly joined, the trial justice's failure to sever the cases infringed upon his right to a fair trial. Upon review, the Supreme Court affirmed the judgments of the Superior Court.

Defendant Juan Diaz appealed his conviction on second-degree murder and one count of using a firearm while committing a crime of violence. On appeal, Defendant argued that the trial justice erred in failing to grant his motion for a judgment of acquittal on the second-degree murder charge because the state failed to provide legally sufficient evidence for a jury to find that he acted with malice in connection with the death of the victim. Furthermore, Defendant argued that the trial justice erred in omitting the phrase "criminal negligence" from his instruction to the jury concerning involuntary manslaughter and instead used "confusing language," which made it difficult for the jury to distinguish the crime of involuntary manslaughter from the crime of murder in the second degree. Upon review, the Supreme Court found that "in order to have properly weighed the charges brought against the defendant, it was crucially important that the jury in this case receive an involuntary manslaughter instruction that included the concept of criminal negligence, thereby creating a distinct and separate charge from that which was given for murder in the second degree." The Court held that the trial justice erred in declining to include that concept in his instruction on involuntary manslaughter. Accordingly, the Court vacated Defendant's judgment of conviction.