Articles Posted in Civil Rights

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The Supreme Court affirmed the judgment of the superior court granting judgment as a matter of law in favor of Defendants in this employment discrimination action. Plaintiff, a former employee of the Town of Lincoln School Department, filed a complaint against the Town of Lincoln, Lincoln School Committee, and the Town’s Finance Director, alleging that she was discriminated against because she advocated for education services for her disabled son, who was a student in the Lincoln school system. The case went to trial. After both sides rested, the trial justice granted Defendants’ motion for judgment as a matter of law. The Supreme Court affirmed, holding that Plaintiff failed to provide sufficient evidence such that a reasonable jury could find that Lincoln’s actions were retaliation for Plaintiff’s advocacy efforts for her son. View "Azar v. Town of Lincoln" on Justia Law

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The Supreme Court vacated the judgments of conviction entered in the superior court following a jury trial convicting Defendant of three counts of assault with a dangerous weapon and one count of carrying a pistol without a license. The Supreme Court held (1) the superior court justice erred in denying Defendant’s motion to suppress evidence seized by police during a warrantless search of Defendant’s home because the state failed to overcome the presumption of unreasonableness that accompanies every warrantless entry into a home; and (2) the admission of the unlawfully seized evidence was not harmless beyond a reasonable doubt. View "State v. Terzian" on Justia Law

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The Supreme Court affirmed the judgment of the superior court following a jury verdict in favor of Plaintiff on a single claim of employment discrimination based on national origin. Both parties appealed the judgment. The Supreme Court denied and dismissed all appeals, holding that the superior court justice (1) did not err in instructing the jury on the law of evidentiary presumptions and its application to this discrimination claim; (2) properly weighed the evidence and did not invade the province of the jury; and (3) did not err when she vacated the jury’s finding that Plaintiff failed to mitigate his damages. Further, Plaintiff was not entitled to judgment as a matter of law on a separate count in the complaint that also alleged employment discrimination. View "Yangambi v. Providence School Board" on Justia Law

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The trial court did not err in declining to suppress the statements Defendant had given tot he police. Defendant was convicted on two counts of first-degree sexual assault. The trial court sentenced Defendant to twenty-five years on both counts, to run concurrently. Defendant appealed the denial of his motion to suppress the statements that he had given to the police, arguing that the State failed to meet its burden of demonstrating, by clear and convincing evidence, that he knowingly, intelligently, and voluntarily waived his constitutional rights under Miranda v. Arizona, 384 U.S. 436 (1966). The Supreme Court affirmed, holding (1) the hearing justice’s finding that Defendant’s statements were not invited by the police but were voluntary statements was correct; (2) Defendant’s post-Miranda statements were admissible because the detectives did not engage in the “question first” interrogation technique found unconstitutional in Missouri v. Seibert, 542 U.S. 600 (2004); and (3) there was no evidence that Defendant failed to comprehend the nature of his rights or the consequences of abandoning them when he made statements while in custody at the police station. View "State v. Sabourin" on Justia Law

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Defendant was charged via a criminal information with breaking and entering a dwelling. After a trial, the trial justice granted Defendant’s motion to pass the case based on based on a comment made by the prosecutor during closing argument. Thereafter, Defendant filed a motion to dismiss the information on grounds of double jeopardy. The trial justice denied Defendant’s motion to dismiss, ruling that the State’s actions were not intended to goad Defendant into seeking a mistrial. The Supreme Court affirmed, holding that the trial justice did not err in determining that the prosecutor did not intentionally goad Defendant into moving for a mistrial. View "State v. Corleto" on Justia Law

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Defendant pleaded nolo contendere to assault in a dwelling house with intent to murder while armed with a dangerous weapon and carrying a pistol on or about his person without a license. While Defendant was on parole, he was arrested and charged with domestic assault and failure to relinquish a telephone. Also while on parole Defendant was charged with breaking and entering. After a hearing, Defendant admitted that he violated the terms and conditions of his probation. Defendant later filed an application for postconviction relief alleging that he was denied the effective assistance of counsel at the probation violation hearing and that he did not knowingly, intelligently, and voluntarily admit a violation of probation. A hearing justice denied Defendant’s application for postconviction relief. The Supreme Court affirmed, holding (1) any alleged deficient performance by Defendant’s attorney was not so prejudicial as to deprive Defendant to a fair trial; and (2) Defendant’s admission was made knowingly, intelligently, and voluntarily. View "Gomes v. State" on Justia Law

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Defendant pled nolo contendere to one count of second-degree sexual assault and one count of intimidation of a witness in a criminal proceeding. Defendant filed an application for postconviction relief alleging that his sentence and conviction were unconstitutional due to the ineffective assistance of counsel. A hearing justice denied postconviction relief, concluding that Defendant made a knowing and intelligent plea at the time of his plea. The Supreme Court affirmed, holding (1) Defendant failed to provide the evidence required to support a claim of ineffective assistance of counsel; and (2) the justice who conducted the postconviction relief hearing did not overlook or misconceive material evidence in arriving at her findings. View "Njie v. State" on Justia Law

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Plaintiff, an attorney employed as a hearing officer for the Rhode Island Department of Elementary and Secondary Education (RIDE), filed a complaint alleging that RIDE and the Rhode Island Board Counsel on Elementary and Secondary Education (collectively, Defendants) violated the Open Meetings Act (OMA) by failing to provide adequate notice of a September 2014 council meeting and by failing to provide any notice of meetings held by the Compensation Review Committee (CRC). The superior court entered summary judgment in favor of Defendants. The Supreme Court reversed in part and affirmed in part, holding (1) Defendants violated the OMA by failing to provide adequate notice of the September 2014 meeting; and (2) the CRC is not a public body and, therefore, is not subject to the OMA. View "Pontarelli v. Rhode Island Board Council on Elementary and Secondary Education" on Justia Law

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Plaintiff was injured on property owned by two individual owners. The unit owners together formed The 18-20 Woodland Court Condominium Association (Defendant). Just prior to the expiration of the relevant three-year statute of limitations, Plaintiff filed a complaint against the individual unit owners, as well as an entity referred to as “XYZ Company.” Nearly an entire year after the expiration of the statute of limitations, Plaintiff sought leave to file an amended complaint in order to add Defendant as a defendant. A hearing justice granted summary judgment in favor of Defendant, concluding that the statute of limitations had run and that Plaintiff’s original complaint had not tolled the statute of limitations because Plaintiff knew of Defendant’s identity at the time she filed the complaint. The Supreme Court affirmed, holding that the statute of limitations on her claim was not tolled pursuant to R.I. Gen. Laws 9-5-20 because Plaintiff knew the identity of Defendant before the statutory period expired. View "Garant v. Winchester" on Justia Law

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In 1994, Applicant entered a plea of nolo contendere to the offense of maintaining a narcotics nuisance. In 2012, Applicant filed a pro se application seeking to vacate his nolo contendere plea. In his application Applicant argued that his plea was not knowing, intelligent, and voluntary and that his counsel provided ineffective assistance. The hearing justice entered judgment for the State and dismissed the application. The Supreme Court affirmed, holding (1) the trial justice did not err in finding that Applicant understood the nature and consequences of his plea; (2) the trial justice properly dismissed Applicant’s claims of ineffective assistance of counsel; and (3) the efforts of postconviction counsel were adequate. View "Reyes v. State" on Justia Law