Justia Rhode Island Supreme Court Opinion Summaries

The case centers on the fatal shooting of a seventeen-year-old during a street altercation in Providence, Rhode Island. The defendant was accused of firing a gun at the victim as she approached a fight between her sister and the defendant’s sister. Witnesses saw the defendant shoot in the victim’s direction, after which she collapsed and later died at the hospital. The defendant was apprehended and charged with second-degree murder and two firearms offenses.At the initial trial in the Rhode Island Superior Court, the prosecution exercised a peremptory strike against the only African-American prospective juror. The trial court allowed the strike, accepting the prosecutor’s asserted concern about potential workplace repercussions for the juror. The jury, which had no African-American members, convicted the defendant on the main charges. On appeal, the Rhode Island Supreme Court upheld the conviction, finding the peremptory strike was based on race-neutral grounds. After a habeas petition was denied by the federal district court, the United States Court of Appeals for the First Circuit reversed, holding that the strike was not race-neutral and ordered the state courts to vacate the conviction unless a new trial was held.At the retrial, again only one African-American venireperson was present. The prosecution sought to remove this juror for cause and, when that was denied, exercised a peremptory challenge, citing the juror’s pending criminal cases and lack of candor. The trial justice ultimately allowed the peremptory challenge, and a jury again lacking African-Americans convicted the defendant. The defendant’s motion for a new trial was denied.On appeal, the Supreme Court of Rhode Island held that the trial court failed to properly conduct the third step of the Batson analysis, which requires a probing inquiry into whether the prosecutor’s race-neutral explanation was genuine or pretextual. The court concluded this failure constituted structural error and vacated the conviction, remanding the case for a new trial. View "State v. Porter" on Justia Law

Two plaintiffs, both incarcerated at the Adult Correctional Institutions in Rhode Island, alleged that the Department of Corrections failed to properly treat their preexisting ankle injuries. They claimed the Department denied them necessary accommodations, including access to elevators and elevation pillows, resulting in painful daily traversal of stairs and inadequate medical care. The plaintiffs filed a complaint citing various federal and state legal provisions, with one count specifically alleging disability discrimination under the Rhode Island Civil Rights Act (RICRA).The United States District Court for the District of Rhode Island denied the Department’s motion for summary judgment on the RICRA claim. The court found genuine disputes of material fact and reasoned that Rhode Island’s State Tort Claims Act (STCA) broadly waived sovereign immunity for “all actions of tort.” The District Court concluded that actions under RICRA sound in tort, meaning the state’s immunity was waived. The Department appealed, and the United States Court of Appeals for the First Circuit certified to the Rhode Island Supreme Court the question of whether RICRA discrimination claims are “actions of tort” under the STCA.The Rhode Island Supreme Court, reviewing the certified question de novo, determined that discrimination claims brought under RICRA are indeed “actions of tort” within the meaning of the STCA. The Court based its holding on the broad definition of tort in Rhode Island law and federal precedent, reasoning that RICRA creates a legal duty and provides remedies for violation of that duty, consistent with tort law. Therefore, claims under RICRA fall within the STCA’s waiver of sovereign immunity, and the certified question was answered in the affirmative. The Court ordered the papers returned to the First Circuit for further proceedings. View "Parente v. Lefebvre" on Justia Law

The plaintiffs operated a daycare center that participated in a federally funded nutrition program administered by the Rhode Island Department of Elementary and Secondary Education. After several years in the program, they received a notice of proposed termination due to alleged serious deficiencies, such as inaccurate meal counts and noncompliance with meal requirements. The plaintiffs requested and received an administrative review, which resulted in a decision upholding their termination from the program, citing uncorrected deficiencies and failure to participate in required training.Following the administrative review, the plaintiffs filed an appeal in the Rhode Island Superior Court, challenging the administrative decision on the grounds that it was unsupported by the record and that mitigating evidence had not been considered. They also argued that the notice of termination failed to inform them of their right to a hearing, in violation of federal regulations. That appeal was pending when, several years later, the plaintiffs brought a second lawsuit in the Superior Court, this time alleging discriminatory disparate treatment and impact under the Rhode Island Civil Rights Act. They claimed that the state agency failed to provide the same level of instruction and feedback as it did to white-owned entities and did not offer materials in Spanish, resulting in harm due to their Hispanic ethnicity.The Rhode Island Superior Court granted the agency’s motion to dismiss the second lawsuit, finding that it was barred by res judicata because the plaintiffs could have raised their discrimination claims in the earlier administrative proceeding. On appeal, the Supreme Court of Rhode Island affirmed the judgment, holding that the plaintiffs had a full and fair opportunity to litigate their discrimination claims before the administrative review officer. The Court concluded that no exception to res judicata applied and that the plaintiffs’ complaint was properly dismissed. View "El Bebe Day Care Center, Inc. v. Rhode Island Department of Elementary and Secondary Education" on Justia Law

Brian Smith was charged with simple assault and second-degree child molestation in 2015 for an incident at a Newport Polo event where he allegedly touched two children inappropriately. He was found guilty of simple assault and sentenced to two years in prison. While this case was pending, Smith was charged with second-degree child molestation in 2015 after his niece reported that he had sexually assaulted her in 2004. Smith pled nolo contendere and was sentenced to ten years, with two years to serve. In 2016, Smith faced additional charges of second-degree child molestation involving three other victims. He pled nolo contendere to two counts and was sentenced to ten years, with six years to serve.The Sex Offender Board of Review classified Smith as a level III sex offender, indicating a high risk to reoffend. Smith objected to this classification and sought review in the Superior Court. The Superior Court magistrate affirmed the board’s classification after considering various risk-assessment tools, police narratives, and Smith’s criminal history. Smith appealed the magistrate’s decision to a Superior Court justice, who also affirmed the classification, concluding that the magistrate had not erred in his decision.The Rhode Island Supreme Court reviewed the case and upheld the Superior Court’s judgment. The Court found that Smith’s procedural due process rights were not violated, as he was given ample opportunity to challenge the board’s findings. The Court also determined that the state had established a prima facie case for the level III classification using validated risk-assessment tools and other relevant evidence. Smith’s arguments regarding the improper consideration of his nolo contendere pleas and the board’s use of unsubstantiated information were rejected. The Court concluded that the board had used reasonable means to collect information and that the state’s interest in protecting the community justified the classification. View "Rhode Island Department of Attorney General v. Smith" on Justia Law

The plaintiff, Xavier T. Vidot, an inmate, filed a complaint against the Rhode Island Department of Corrections (RIDOC) and its officials, alleging that they failed to provide inmates with a daily minimum of 8.5 hours outside their cells, in violation of RIDOC's internal policy and a state statute. The plaintiff sought a writ of mandamus, a declaration of violation, and a permanent injunction.The defendants moved to dismiss the complaint, arguing that RIDOC's internal policies do not establish a private cause of action for inmates and that the application of these policies involves discretionary decisions. The plaintiff responded, asserting that the defendants had a ministerial legal duty to operate in accordance with RIDOC's policy and that the statute does not afford the defendants any discretion except that which is allowed by internal policies.The Superior Court granted the defendants' motion to dismiss, reasoning that the policies governing these issues are internal and discretionary, as they are not codified in the statute. The plaintiff appealed this decision.The Supreme Court of Rhode Island affirmed the Superior Court's decision. The court found that the statute outlining the duties of the director of the Department of Corrections clearly bestows upon the director a great deal of discretion in the exercise of his or her duties. The court also found that both the previous and amended versions of RIDOC's policy contemplate that RIDOC must exercise its discretion in "exigent circumstances," in the case of "emergencies," or in the event of "overriding conditions"—all for the purpose of maintaining a "safe and orderly operation of the facility." Therefore, the court concluded that the hearing justice did not err in denying relief in the form of a writ of mandamus and in granting the motion to dismiss. View "Vidot v. Salisbury" on Justia Law

Edward Mather, the defendant, was charged with multiple counts of domestic assault, vandalism, and violation of a no-contact order. Following his arraignment, he was ordered to undergo a psychiatric evaluation to determine his competency to stand trial. The evaluation concluded that Mather was incompetent to stand trial and required hospitalization. Subsequently, he was committed to an outpatient facility, LaBelle House Group Home, under the custody of the Department of Behavioral Healthcare, Developmental Disabilities and Hospitals (BHDDH).The Superior Court held a commitment hearing and based on a report from BHDDH, found Mather remained incompetent to stand trial. The court ordered Mather to remain committed to BHDDH's custody but allowed him to be placed in an outpatient facility without endangering himself or others. The court also ordered that if Mather violated the conditions of the order, engaged in threatening or aggressive behavior, or required hospitalization, he should be immediately returned to Eleanor Slater Hospital.Mather filed a petition to discharge from the detention order of commitment in both of his pending criminal matters. He argued that his continued institutionalization at the outpatient facility restricted his liberty and violated due process. The trial justice denied Mather's petitions, reasoning that his commitment to the outpatient facility did not constitute "detention" pursuant to the relevant statute. Mather sought review of the decision, and the Supreme Court of Rhode Island granted the petitions, consolidated the cases for review, and issued the writ.The Supreme Court of Rhode Island quashed the orders of the Superior Court and remanded the matter for further proceedings. The court held that the trial justice committed a reversible error of law when he denied the petitions to discharge from detention orders of commitment. The court concluded that Mather's continued commitment no longer bore a reasonable relationship to the purpose of his commitment under the relevant statute. The court held that where a defendant is found to be incompetent to stand trial and competency is nonrestorable prior to the statutory dismissal period, the defendant is entitled to be discharged from detention under the order of commitment thirty days thereafter. View "State v. Mather" on Justia Law

The plaintiff, Dania Mateo, filed a case against Davidson Media Group Rhode Island Stations, LLC and several of its employees, which included 22 counts alleging violations of Rhode Island's Fair Employment Practices Act (RIFEPA) and Civil Rights Act (RICRA) as well as claims of sexual harassment, civil conspiracy, intentional infliction of emotional distress, negligent infliction of emotional distress, assault and battery, negligence, false imprisonment, defamation, and conspiracy to commit defamation. The case was pending for nearly 14 years.Mateo appealed a Superior Court decision granting partial summary judgment in favor of certain defendants. The defendants cross-appealed, arguing that the hearing justice erred in granting partial final judgment because he failed to make an express determination that there was no just reason for delay, as required by Rule 54(b) of the Superior Court Rules of Civil Procedure.The Supreme Court of Rhode Island found the defendants’ cross-appeal meritorious. The Court ruled that the hearing justice erred in granting partial final judgment because he failed to determine whether the criteria clearly set forth in Rule 54(b) had been satisfied. The Court held that the judgment must be vacated and the case remanded to the Superior Court for further proceedings. As a result, the Court did not reach the issues raised in the plaintiff's appeal. View "Mateo v. Davidson Media Group Rhode Island Stations, LLC" on Justia Law

The Supreme Court vacated the orders of the superior court granting Defendants' motions to suppress evidence of approximately ninety-four pounds of marijuana seized from one defendant's vehicle during a traffic stop, holding that the trial justice erred in granting Defendants' motions to suppress.Junjie Li was operating a vehicle and Zhong Kuang was in the passenger seat when a law enforcement officer initiated a traffic stop. While conversing with Li, the officer noticed Li began to exhibit nervous behavior and detected an order of marijuana coming from inside Kuang's vehicle. After a dog sniff, officers discovered marijuana. Li and Kuang moved, individually to suppress the marijuana. The trial justice granted the motions to suppress, holding that the extension of the traffic stop beyond its original scope was unreasonable because the officer did not have independent reasonable suspicion to prolong the stop. The Supreme Court vacated the superior court's orders, holding that the trial justice erred in concluding that the officer did not possess reasonable suspicion to prolong the stop based on the totality of the circumstances. View "State v. Li" on Justia Law

The Supreme Court affirmed the orders of the superior court granting motions to suppress filed by Defendants Jerome Joseph and Voguel Figaro, holding that the hearing justice did not err in granting Defendants' suppression motions.Figaro moved to suppress physical evidence seized as the result of a motor vehicle stop, arguing that the officer unconstitutionally prolonged the stop to perform a dog sniff. Joseph also filed a motion to suppress and joined the memorandum supporting Figaro's suppression motion. The hearing justice granted the motions to suppress, holding that reasonable suspicion did not support the prolonged traffic stop of Figaro's vehicle. The Supreme Court affirmed, holding that the hearing justice properly found that the state police lacked reasonable suspicion to detain Defendants. View "State v. Joseph" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of three counts of first-degree sexual assault, following a jury trial, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme eCourt held that the trial justice (1) did not violate Defendant's constitutional right to present a defense by excluding the proposed expert testimony of Dr. Patricia R. Recupero as not relevant under Rule 401 of the Rhode Island Rules of Evidence; (2) did not err in instructing the jury that there was no need for certain testimony to be corroborated in order to support a guilty verdict; and (3) did not abuse his discretion in limiting the redirect examination of Defendant about his preparation for trial. View "State v. Robinson" on Justia Law