Justia Civil Rights Opinion Summaries

Following a jury trial, Defendant Kayborn Brown was convicted of first-degree robbery and sentenced to forty years' incarceration. The Supreme Court affirmed the judgment of conviction, holding that the trial justice (1) did not err in denying Defendant's motion to suppress complainant's out-of-court identification from a photographic array, as the identification was not impermissibly suggestive or improperly tainted; and (2) did not abuse its discretion under R.I. R. Evid. 403 by denying Defendant's motion in limine to exclude evidence of a fraudulent charge to the complainant's credit card that occurred shortly after the robbery, as the evidence connected Defendant to the crime.

Kevin Lyons was convicted of two counts of first-degree child molestation. The Supreme Court affirmed. Lyons subsequently filed an application for postconviction relief, arguing that he had been prejudiced by ineffective assistance of counsel. The superior court denied the application, and the Supreme Court affirmed. Lyons then filed a second application for postconviction relief, relying on an array of arguments. The superior court denied Lyons' second application, finding that each of Lyons' claims either lacked merit or were barred by the doctrine of res judicata. The Supreme Court affirmed, holding that Lyons failed to carry his burden of proving, by a preponderance of the evidence, that postconviction relief was warranted.

A jury found Applicant Rudy Sifuentes guilty of first-degree murder in a manner involving torture and aggravated battery, for which he was sentenced to life imprisonment. Applicant subsequently filed a pro se application for postconviction relief, alleging ineffective assistance of counsel and a violation of his constitutional rights. The superior court denied Applicant's application. Applicant appealed, arguing that the hearing justice erred in denying his application by accepting "the memoranda of investigating counsel in lieu of evidence." The Supreme Court affirmed, holding that under the circumstances, the hearing justice properly adequately followed the procedures set forth in Rhode Island's Postconviction Remedy Statute and properly denied Applicant's postconviction-relief application.

Defendant Gary Gromkiewicz entered a plea of nolo contendere to one count of first-degree robbery and was sentenced to twenty years incarceration, thirteen years suspended with probation. The superior court subsequently adjudged Defendant to be in violation of his probation. Defendant appealed, arguing that the trial justice erred by finding that he had violated his probation by failing to keep the peace and remain on good behavior. The Supreme Court affirmed, holding that the trial justice acted well within her discretion when she assessed the credibility of the testifying witnesses and did not act arbitrarily or capriciously in finding that Defendant violated the terms of his probation.

After a jury trial, Wesley Spratt was found guilty of murder while committing or attempting to commit robbery, first-degree robbery, carrying a pistol without a license, and committing a crime of violence while armed with a firearm. The Supreme Court affirmed the convictions. Spratt subsequently filed a petition for postconviction relief. The superior court eventually denied the petition after a hearing on the merits. The Supreme Court affirmed, holding (1) the hearing justice did not err in finding that Spratt's contention that a courthouse identification of Spratt by a witness was improperly orchestrated by the state was without merit; (2) Spratt did not meet his burden of showing sufficient evidence of the State's alleged coercion of the witness; (3) Spratt did not meet his burden of showing that any discovery violation occurred; (4) the hearing justice correctly rejected Spratt's claim of unlawful sentencing; (5) Spratt's allegations of ineffective assistance of counsel were unavailing; and (6) the hearing justice did not err in finding that the evidence presented at trial was sufficient to convict Spratt.

After a probation violation hearing, Defendant Santo Jensen was found to have violated the terms and conditions of his probation for allegedly sexually assaulting a six-year-old. Jensen was sentenced to serve the seven-year suspended portion of a ten-year sentence that had previously been imposed pursuant to his conviction on one count of breaking and entering a dwelling. The Supreme Court affirmed the judgment of the superior court, holding that the hearing justice did not act arbitrarily or capriciously in (1) assessing the credibility of the complaining witness or in adjudicating defendant to be a probation violator; (2) crediting the complaining witness's testimony; or (3) weighing the evidence presented at the probation violation hearing to support the conclusion that Defendant had violated his probation.

Applicant Jerry Steele entered a plea of nolo contedere to assault with a dangerous weapon. Applicant subsequently filed a pro se motion for postconviction relief, alleging, inter alia, that he was forced against his will to enter a guilty plea. After the superior court appointed an attorney for applicant, the court denied the motion. Applicant appealed, contending that his court-appointed attorney provided ineffective assistance of counsel during the postconviction-relief hearing. The Supreme Court affirmed, holding that Applicant's contention concerning alleged ineffective assistance of counsel at the postconviction-relief hearing was not property before it, as Applicant's argument on appeal was not presented to the superior court.

Defendant Yoneiry Delarosa appealed from a superior court judgment adjudicating him a violator of probation. The Supreme Court affirmed the judgment of the superior court, holding that the hearing justice did not err (1) by crediting the testimony of a witness after she was offered a favorable plea disposition by the State to testify against Defendant; (2) in overruling defense counsel's objection to certain testimony by the witness about which Defendant alleged he had not been apprised prior to the hearing because the witness revealed the information for the first time at the hearing and no written or recorded statement existed on this particular issue; and (3) by failing to allow defense counsel or Defendant the opportunity to address the court prior to sentencing, as the hearing justice correctly followed precedent in so ruling.

Defendant Christopher Smith was found guilty of first-degree child molestation sexual assault and second-degree child molestation sexual assault arising from a series of assaults upon a thirteen-year-old girl. The Supreme Court affirmed, holding that the trial justice did not abuse his discretion by (1) denying Defendant's motion for a new trial, as there was sufficient evidence to support the jury's verdict; and (2) permitting the State, over Defendant's objection, to cross-examine Defendant about weapons training he received while in the military, as the trial justice properly weighed the probative value of the evidence against any potential prejudicial effect in overruling Defendant's objection.

Defendant Isabel Traveras was convicted of possession of an enumerated quantity of cocaine, for which she received a ten-year suspended sentence, with probation. On appeal, Defendant challenged the denial of her motion to suppress, alleging that the arresting police officers violated her Fourth Amendment rights when they (1) detained her unlawfully at a traffic stop and conducted a pat-down search without a reasonable articulable suspicion that she might be armed and dangerous, and (2) exceeded the scope of a permissible pat-down search by directing her to unzip and open her jacket. The Supreme Court affirmed, holding that, based on the totality of the circumstances, (1) the officers acquired the requisite reasonable suspicion to approach Defendant in the vehicle in which she was sitting as a passenger; and (2) the credible evidence was sufficient to establish that an officer's request to Defendant to open her jacket was reasonable and was a less-intrusive search designed to ensure officer safety.