DeJesus v. State

Summary

The Rhode Island Supreme Court vacated the denial of Jose DeJesus’s application for post-conviction relief and remanded for an evidentiary hearing on his ineffective-assistance-of-counsel claims. The court affirmed the determination that his Confrontation Clause challenge was procedurally barred because it had been addressed on direct appeal.

Holdings

1. The challenge to the recorded statement was procedurally barred by res judicata because the Supreme Court had addressed the issue on direct appeal.
2. The Superior Court could not properly deny DeJesus's ineffective-assistance application on the existing record because he was not given a meaningful opportunity to present his claims and the factual findings appeared to rest on appointed counsel's no-merit memorandum rather than trial-transcript evidence or evidence presented at a post-conviction hearing.

Questions Presented

1. Whether DeJesus's Sixth Amendment Confrontation Clause challenge to a recorded statement was procedurally barred because the issue had been decided on direct appeal.
2. Whether the Superior Court properly denied DeJesus's application for post-conviction relief on his ineffective-assistance-of-counsel claims without providing a meaningful opportunity to present them and without conducting an evidentiary hearing.

Disposition

vacated