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State v. Oliveira
Supreme Court of Rhode Island · 2005-08-05 · cited 58×
In State v. Oliveira, three defendants were tried on charges stemming from a 1995 drug-related shooting in Providence that resulted in the death of Grady Bolden during an attempted cocaine transaction. A jury convicted Gahlil Oliveira and Victor St. Hill of first-degree felony murder and all three defendants of conspiracy to violate the Rhode Island Controlled Substances Act. The Rhode Island Supreme Court reversed the felony-murder convictions, holding that the underlying drug conspiracy did not qualify as a predicate felony for first-degree felony murder under the statute, while affirming the conspiracy convictions based on sufficient evidence of an agreement to possess and distribute controlled substances. The court emphasized that first-degree felony murder applies only to homicides occurring during specifically enumerated predicate offenses as designated by the legislature.
criminal law
In Re MacKenzie C.
Supreme Court of Rhode Island · 2005-07-18 · cited 14×
The case involved a nine-week-old infant, Mackenzie, who sustained nineteen unexplained fractures, prompting the Department of Children, Youth and Families (DCYF) to file petitions in Family Court for the child's commitment due to abuse and for termination of parental rights on grounds of unfitness. The trial justice initially granted the abuse petition based on findings that the injuries were non-accidental and caused by the parents, but after additional hearings, medical expert testimony regarding possible conditions like temporary brittle bone disease, and psychiatric evaluations, the court reversed its ruling, finding that DCYF had failed to prove abuse by clear and convincing evidence and that reunification served the child's best interests; it dismissed both petitions. The Rhode Island Supreme Court affirmed the dismissals, holding that the trial justice acted within his discretion in reconsidering the evidence and that the justice system had provided adequate opportunity for all parties to present their cases. The court declined to address the termination petition separately since the underlying abuse finding was not sustained.
family law
Tanner v. Town Council of Town of East Greenwich
Supreme Court of Rhode Island · 2005-07-18 · cited 100×
The case concerned whether the Town Council of East Greenwich violated the Open Meetings Act when it voted to appoint members to the zoning board and planning board at an October 2001 meeting. The posted agenda listed only interviews for potential appointees, but the council proceeded to make three appointments after the interviews. The Superior Court granted summary judgment to plaintiff Tanner, holding that the notice was inadequate because it did not inform the public that voting would occur, and the Rhode Island Supreme Court affirmed that ruling on the ground that the Open Meetings Act requires notice sufficient to alert citizens to the policy-making actions being considered. The Supreme Court vacated the award of attorney’s fees, however, because the record did not establish a knowing and willful violation.
procedure
State v. Hallenbeck
Supreme Court of Rhode Island · 2005-07-13 · cited 78×
In State v. Hallenbeck, the defendant was convicted of manslaughter after a jury trial for the stabbing death of Glenn Petersen at the Warwick Mall, following his acquittal on the charged offense of murder. The defendant appealed, raising six claims of error by the trial justice, including improper jury instructions on self-defense and manslaughter, denial of his motions for judgment of acquittal and a new trial, exclusion of the victim's criminal record, admission of a crime scene photograph, and sentencing issues. The Rhode Island Supreme Court affirmed the conviction and sentence, holding that the trial court did not commit reversible error on any of the asserted grounds and that the defendant's challenge to the denial of his motion to reduce sentence was not properly before the court on appeal.
criminal lawprocedure
State v. Linde
Supreme Court of Rhode Island · 2005-07-07 · cited 45×
The case involved Eddie Linde, convicted of second-degree murder and related felonies after a shooting death at a Rhode Island motel stemming from a workplace dispute among ironworkers. Linde appealed his convictions, claiming error in the denial of his motion to suppress evidence seized from under his motel room mattress via a warrantless search to which his roommate consented, and in the trial court's refusal to instruct the jury on self-defense. The Rhode Island Supreme Court affirmed the judgment of conviction. It held that the roommate had common authority over the shared motel room sufficient to consent to the search under Fourth Amendment standards, and that the evidence did not support giving a self-defense instruction.
criminal lawprocedure
State v. Disla
Supreme Court of Rhode Island · 2005-05-26 · cited 38×
In State v. Disla, the defendant appealed his Superior Court convictions for delivering heroin and conspiring to violate the Rhode Island Controlled Substances Act, arguing insufficient evidence for the conspiracy count and that the trial justice should have declared a mistrial after improper testimony from a police detective. The detective had described an alleged coconspirator as a known narcotics user and referenced a surveillance photograph of the defendant taken on a different date and at a different location than the charged offense. The state conceded on appeal that it had presented insufficient evidence to support the conspiracy conviction. The Supreme Court reversed the conspiracy conviction, affirmed the delivery conviction, and held that the trial justice's cautionary instructions to the jury adequately cured any potential prejudice from the detective's statements.
criminal law