Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of one count of felony domestic assault, two counts of assault with a dangerous weapon, and one count of simple domestic assault after previously having been convicted twice of domestic assault. The Supreme Court affirmed. Defendant later filed an application for postconviction relief, alleging that his trial counsel was ineffective because he stipulated to the fact that Defendant had two prior convictions for domestic violence in the presence of the jury. The Supreme Court affirmed, holding that trial counsel’s performance was not deficient, and even if Defendant were able to establish that his trial counsel was ineffective, Defendant’s right to a fair trial was not prejudiced by his trial counsel’s conduct. View "Snell v. State" on Justia Law

A criminal complaint was filed against Defendant charging him with burglary. After a combined bail and violation hearing, a hearing justice found that Defendant failed to be of good behavior and that Defendant violated the terms of his violation. Defendant appealed, arguing, inter alia, that evidence obtained from the search of a vehicle should have been suppressed because it was obtained from an illegal search and seizure. The Supreme Court affirmed, holding (1) Defendant lacked standing to contest the legality of the search of the vehicle; (2) even assuming the police illegally obtained the evidence, the exclusionary rule did not apply at Defendant’s probation revocation hearing; and (3) the hearing justice did not act arbitrarily or capriciously in finding that Defendant violated his probation. View "State v. Ditren" on Justia Law

After a jury trial, Defendant was convicted of two counts of assault with a dangerous weapon and one count of simple assault. On appeal, Defendant argued, among other things, that the prosecutor improperly vouched for the credibility of two witnesses during her closing argument. The Supreme Court affirmed the convictions, holding (1) the trial justice did not abuse his discretion by allowing the state to impeach Defendant’s credibility with his fourteen prior criminal convictions; and (2) although a portion of the prosecutor’s closing argument was akin to vouching, the trial justice did not err by refusing to pass the case. View "State v. Whitfield" on Justia Law

After a jury trial, Defendant was found guilty of two counts of second-degree child molestation sexual assault. The Supreme Court affirmed the superior court’s judgment of conviction and its denial of Defendant’s motion for a new trial, holding (1) the trial justice did not abuse his discretion in denying Defendant’s motion to pass the case after the prosecutor engaged in an improper line of questioning to a witness, as any prejudice which may have resulted was cured by the trial justice’s instruction to the jury; and (2) the trial justice did not misconceive or overlook material testimony and did not otherwise commit clear error in denying Defendant’s motion for a new trial. View "State v. Hie" on Justia Law

In 1990, Applicant was convicted of one count of first-degree sexual assault. In 2001, Applicant filed a pro se application for postconviction relief, alleging ineffective assistance of counsel and trial error. In 2005, the hearing justice denied the application. The Supreme Court affirmed, holding that the hearing justice properly did not commit clear error or misconceive material evidence in rendering his decision, as (1) Applicant’s claims relating to alleged errors committed by the trial justice were barred by the doctrine of res judicata; and (2) Applicant failed to show to his trial counsel’s representation fell below an objective standard of reasonableness. View "Lamoureux v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree child molestation and one count of second-degree child molestation. The Supreme Court affirmed the convictions on direct appeal. Appellant subsequently filed an application for postconviction relief, arguing that his trial counsel provided ineffective assistance. The trial justice denied the application, concluding that Appellant failed to establish that his counsel’s performance was deficient. The Supreme Court affirmed, holding that the trial justice did not err in finding that trial counsel performed at a high level and in thus denying Appellant’s application for postconviction relief. View "Merida v. State" on Justia Law

After a jury trial, Defendant was convicted of carrying a pistol without a license and possession of a firearm by a person previously convicted of a crime of violence. The Supreme Court affirmed the judgment of conviction, holding (1) the trial justice did not err in denying Defendant’s motion for a judgment of acquittal because the the State produced sufficient evidence at trial from which a jury could infer beyond a reasonable doubt that Defendant possessed the handgun; and (2) the trial justice did not violate Defendant’s right to effective assistance of counsel by restricting defense counsel’s closing argument. View "State v. Ferrer" on Justia Law

Defendant was charged with two counts of first-degree robbery in connection with two armed robberies. Defendant filed several motions to suppress evidence obtained by police detectives following his arrest. A hearing justice granted Defendant’s motion to suppress certain evidence under the exclusionary rule to the Fourth Amendment to the United States Constitution because the evidence was gathered after an “illegal” extra-jurisdictional arrest. The Supreme Court vacated the order of the superior court, holding (1) the detectives’ actions in arresting Defendant outside their jurisdiction were in excess of their authority; but (2) the exclusionary rule of the Fourth Amendment did not mandate the suppression of the evidence obtained in this case. View "State v. Morris" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder and sentenced to life imprisonment. Appellant filed a pro se application for postconviction relief alleging that he received ineffective assistance of counsel at trial. Appellant also filed a motion to appoint counsel. Counsel was appointed to investigate Appellant’s postconviction-relief claims in light of the Court’s holding in Shatney v. State. Counsel subsequently filed a Shatney report and requested that the court permit her to withdraw her appearance on Appellant’s claims of ineffective assistance of counsel. The trial court allowed counsel to withdraw from the case, and Appellant proceeded pro se on his postconviction relief claims. Following a hearing, the trial justice denied and dismissed Appellant’s application for postconviction relief. The Supreme Court vacated the judgment of the superior court, holding that the trial justice did not follow the appropriate procedure mandated by Shatney by not allowing Appellant an opportunity to be heard on the merits of his application before allowing the appointed attorney to withdraw. Remanded with directions to appoint counsel to Appellant in accordance with section R.I. Gen. Laws 10-9.1-5 for investigation and, if appropriate, litigation of Appellant’s allegations. View "Ramirez v. State" on Justia Law

Plaintiffs, school committees of Woonsocket and Pawtucket and unnamed students, parents, and the superintendents from both districts, brought suit against the legislative and executive branches of Rhode Island’s state government challenging the state’s school funding formula. Specifically, Plaintiffs alleged violations of the Education Clause as well as violations of their substantive due process and equal protection rights because the formula failed to allocate adequate resources to less affluent communities. The superior court granted Defendant’s motion to dismiss the complaint. The Supreme Court affirmed, holding (1) prior case law as well as the separation of powers doctrine warranted dismissal of Plaintiffs’ Education Clause claim; and (2) Plaintiffs’ complaint was insufficient to establish potential substantive due process claims. View "Woonsocket Sch. Comm. v. Chafee " on Justia Law