Justia Rhode Island Supreme Court Opinion Summaries

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The Supreme Court affirmed the decision and judgment of the superior court denying Defendant's motion to correct an illegal sentence pursuant to Rule 35(a) of the Superior Court Rules of Criminal Procedure, holding that Defendant waived his argument on appeal.Defendant pled guilty to several counts related to a gang-related shooting, including first-degree murder, weapons charges, assault, and conspiracy. The trial justice sentenced Defendant to a mandatory term of life imprisonment for first-degree murder, fifty years' imprisonment for offenses ancillary to the shooting, and an additional consecutive ten-year term of imprisonment pursuant to the criminal street gang enhancement statute. Defendant later filed a motion to correct his sentence, asserting that the State had failed to timely notify him of its intention to pursue the criminal street gang sentencing enhancement. The trial justice denied the motion, concluding that Defendant had expressly waived his right to timely notice as part of his agreement with the State. The Supreme Court affirmed, holding that Defendant's waiver of notice under the criminal street gang enhancement statute was valid, and therefore, Defendant's motion to correct sentence was properly denied. View "State v. Briggs" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court convicting Defendant of simple domestic assault or battery and domestic refusal to relinquish or to damage or to obstruct telephone, holding that there was no error in the trial justice's rulings in this case.On appeal, Defendant argued that the trial court committed reversible error when it impermissibly prevented and restricted his cross-examination of the complaining witness, in violation of the Sixth Amendment. The Supreme Court affirmed, holding that, given the wide discretion afforded to trial justices in limiting the extent of cross-examination, the trial justice did not err in its challenged rulings. View "State v. Garcia" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's judgment of conviction and the denial of his motion for a new trial, holding that the trial justice did not err or abuse her discretion in denying Defendant's motion for a new trial.Following a jury trial, Defendant was convicted of four counts of first-degree child molestation and sexual assault. On appeal, Defendant argued that the trial justice erred by denying his motion for a new trial because the trial justice overlooked material evidence. The Supreme Court affirmed, holding that the trial justice articulated adequate grounds for denying Defendant's motion for a new trial and that the trial justice did not overlook material evidence. View "State v. Vazquez" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed a superior court judgment of conviction for second-degree sexual assault following a 1993 jury trial and a 2019 superior court judgment adjudicating Defendant a probation violator for his failure to appear for execution of his sentence for that 1993 conviction, holding that there was no error.In 1993, a jury found Defendant guilty of one count of second-degree sexual assault and sentenced him to ten years' imprisonment. Defendant failed to appear for execution of his sentence, and a superior court clerk entered a judgment of conviction and commitment. In 2017, Defendant was arrested and extradited to Rhode Island. In 2018, a second trial justice ordered Defendant to begin serving the unsuspended portion of his original sentence. Thereafter, the State filed a notice of probation violation alleging that Defendant failed to comply with a probation condition when he failed to appear for execution of his sentence. The trial justice declared Defendant a violator of the terms of his probation and sentenced him to an additional three years' incarceration. The Supreme Court affirmed, holding that the trial justice did not err in adjudging Defendant a probation violator for his failure to appear for execution of his sentence. View "State v. Bienaime" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's conviction of second-degree child molestation sexual assault, holding that the trial justice did not err in denying Defendant's motion for a mistrial.On appeal, Defendant argued that the State posed a question to the complaining witness that was highly prejudicial and violated a pretrial order, and therefore, his motion for a mistrial was improperly denied. The Supreme Court affirmed, holding (1) there was nothing in the record to suggest that the jurors could have been so inflamed by the brief exchange such that they would be unable to examine the evidence in a calm and dispassionate manner; and (2) therefore, the superior court did not err in denying Defendant's motion for a mistrial. View "State v. Barboza" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of voluntary manslaughter, holding that there was no error in the proceedings below.On appeal, Defendant argued that the jury erroneously rejected his claim of self-defense when it returned a verdict of guilty of voluntary manslaughter. The Supreme Court affirmed, holding (1) in its role as fact-finder, the jury was free to reject Defendant's claim of self-defense; and (2) because this issue was never before the trial justice in the context of a motion for a new trial or a motion for judgment of acquittal, the trial justice did not weigh the evidence or pass upon the credibility of witnesses. View "State v. Stevens" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the final decree of the superior court foreclosing Respondent's right of reception for property sold at a tax sale, holding that there was no error.Petitioner purchased the property at issue in this case at a tax sale. More than one year after the tax sale and the recording of the deed, Petitioner filed a petition seeking to foreclose Respondent's right of redemption. The superior court held a hearing on the petition and determined that Respondent was in default and that Petitioner was entitled to its requested relief. The Supreme Court affirmed, holding that Respondent waived all of the arguments that he raised on appeal. View "E.T. Investments, LLC v. Riley" on Justia Law

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In these consolidated appeals, the Supreme Court reversed two judgments of the superior court entered in favor of Petitioners, a group of taxpayers who challenged the City of Providence's tax assessments on their properties for tax years 2014 and 2015, holding that the trial justice erred.The trial justice ruled that a revaluation conducted in 2013 of property values was illegal and invalid and that the tax bills for the relevant tax years shall be revised based on the 2012 revaluation. The superior court entered judgment in favor of Petitioners in excess of $1.5 million. The Supreme Court reversed, holding that the trial justice improperly weighed the evidence and erred as a matter of law in finding that the 2013 revaluation was illegal, invalid, selective, arbitrary, and discriminatory. View "Athena Providence Place v. Pare" on Justia Law

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The Supreme Court affirmed the decree of the family court terminating Mother's parental rights to her son, holding that the family court did not err.The trial justice found by clear and convincing evidence that Mother was unfit to parent the child and that it was in the child's best interest that Mother's parental rights be terminated. The Supreme Court affirmed, holding (1) there was sufficient evidence in the record to support the trial justice's finding that Mother was unfit given her failure to engage fully in the services provided by the Department of Children, Youth, and Families and lack of protective capacity; and (2) the trial justice's decision to terminate Mother's parental rights was proper. View "In re Domenic B." on Justia Law

Posted in: Family Law
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The Supreme Court affirmed the judgment of the superior court in favor of Defendants in this case involving an allegedly defamatory report that was broadcast on the evening news, holding that the hearing justice did not err in granting Defendants' motions for summary judgment on all counts in the complaint.Captain Russell Henry of the Cranston Police Department filed this action against Media General Operations, Inc. and several individuals alleging that NBC 10 WJAR, which was owned and operated by Media General, published reports that were false and defamatory as to Captain Henry. The hearing justice concluded that Captain Henry was a public official and that he could not prove, by clear and convincing evidence, that Defendants acted with actual malice in disseminating the allegedly defamatory information at issue. The Supreme Court affirmed, holding (1) Captain Henry was a public official at the time of the broadcast; and (2) there was insufficient evidence to allow a reasonable juror to conclude that broadcast was made with actual malice. View "Henry v. Media General Operations, Inc." on Justia Law

Posted in: Personal Injury