Jeremy Motyka v. State of Rhode Island
172 A.3d 1203
R.I.2017Background
- Jeremy Motyka was convicted in 2001 of first-degree murder and first-degree sexual assault and sentenced to life without parole on the murder count; this Court affirmed that conviction in State v. Motyka.
- Motyka filed a postconviction relief (PCR) application in 2009; the denial was vacated and remanded in Motyka II after the State conceded the trial court failed to follow Shatney procedures.
- On remand Motyka filed an amended (operative) PCR application; court-appointed PCR counsel filed a motion to withdraw with a no‑merit memorandum and sought to strike Motyka’s pro se filings.
- A December 3, 2014 hearing addressed counsel’s motion to withdraw and the State’s motion to dismiss; the hearing justice denied Motyka’s application, granted counsel’s withdrawal, and dismissed the PCR petition.
- Motyka appealed, arguing he was denied an evidentiary hearing as required for life‑without‑parole first PCR applications and that counsel failed to investigate and pursue claims including actual innocence, prosecutorial misconduct, double jeopardy, insufficiency of jury instructions, ineffective assistance of trial and appellate counsel, due‑process and equal‑protection violations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Motyka was entitled to an evidentiary hearing on his first PCR application given life without parole sentence | Motyka: Tassone entitles him to an evidentiary hearing; the Dec. 3, 2014 proceeding was not such a hearing | State: Dec. 3, 2014 proceeding and counsel’s no‑merit filing justified dismissal without full evidentiary hearing | Court: December 3, 2014 proceeding did not satisfy Tassone or Shatney; an evidentiary hearing is required and Shatney’s procedures are abrogated for initial PCRs by LWOP applicants; remand for appointment of counsel and further proceedings under Tassone |
| Whether Shatney procedures remain applicable to initial PCRs in LWOP cases | Motyka: relied on Shatney procedural protections plus Tassone’s evidentiary-hearing rule | State: urged dismissal under Shatney/no‑merit process as applied below | Court: Shatney and Tassone are inconsistent for LWOP initial PCRs; Shatney is abrogated in that context and Tassone’s mandatory evidentiary hearing controls |
| Adequacy of appointed PCR counsel’s representation (investigation/discovery) | Motyka: counsel failed to investigate/discover and concurrently advised him while arguing no‑merit | State: no‑merit memorandum justified withdrawal and dismissal | Court: Did not resolve on merits because procedural error (lack of required evidentiary hearing) warranted remand; directed appointment of counsel for proper proceedings |
| Whether the hearing justice properly relied on counsel’s no‑merit memorandum to dismiss the PCR petition | Motyka: hearing justice improperly let counsel’s no‑merit memorandum determine merits without evidentiary hearing | State: argued memorandum and hearing supported denial | Held: The hearing justice improperly treated the no‑merit memorandum as dispositive; dismissal without evidentiary hearing was improper; judgment vacated and remanded |
Key Cases Cited
- State v. Motyka, 893 A.2d 267 (R.I. 2006) (direct appeal affirming conviction)
- Motyka v. State, 91 A.3d 361 (R.I. 2014) (mem.) (vacating PCR denial and remanding for Shatney compliance)
- Shatney v. State, 755 A.2d 130 (R.I. 2000) (procedure for counsel withdrawal/no‑merit memorandum and applicant’s right to be heard)
- Tassone v. State, 42 A.3d 1277 (R.I. 2012) (requiring evidentiary hearing for initial PCRs by LWOP applicants)
- Merida v. State, 93 A.3d 545 (R.I. 2014) (standard of review for constitutional claims in PCR proceedings)