Justia Rhode Island Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgments of the superior court convicting Defendant following a jury trial for larceny of an automobile and adjudicating him a probation violator, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued, among other things, that the trial court erred in denying his motion to suppress certain evidence collected as a result of a warrantless search of his real-time cell-site location information (CSLI). The Supreme Court disagreed and affirmed, holding (1) the acquisition of real-time CSLI qualifies as a search under the Fourth Amendment for which a warrant is required; (2) any error in the trial justice's determination that the exigent circumstances exception to the warrant requirement applied to the facts of this case was harmless; (3) the trial justice did not abuse his discretion in denying Defendant's motion to exclude certain testimony, and any error in allowing other testimony to be admitted at trial was harmless; and (4) Defendant waived his last argument for appeal. View "State v. Sinapi" on Justia Law

The Supreme Court affirmed the judgment of the superior court in granting summary judgment in favor of Defendants, Rhode Island College and related individuals, on the grounds of qualified immunity, holding that Plaintiff was not entitled to relief on his claims of error.Plaintiff brought this action seeking equitable relief and damages under 42 U.S.C. 1983 and 1988 on the grounds that Defendants' conduct toward him during his Master of Social Work program violated his First and Fourteenth Rights. The superior court concluded that Defendants were entitled to qualified immunity and granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding that Plaintiff's arguments on appeal were unavailing. View "Felkner v. R.I. College" on Justia Law

The Supreme Court affirmed the judgment of the trial court deciding to grant Defendant's request to represent himself and denying his motion for a new trial, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that his waiver of his right to the assistance of counsel was not valid and that the trial justice erred when she denied his motion for a new trial. The Supreme Judicial Court affirmed, holding (1) there was no error in the trial justice's decision allowing Defendant to discharge his attorney when and as he did; and (2) the record established that Defendant made a voluntary, knowing, and intelligent waiver of his right to the assistance of counsel; and (3) the trial justice did not err in denying Defendant's motion for a new trial. View "State v. Delossantos" on Justia Law

The Supreme Court vacated the order of the superior court granting Defendant's motion to suppress two statements to Warwick police detectives in the course of their investigation, holding that the superior court abused its discretion.The trial justice suppress statements based on its findings that Defendant was in custody when he voluntarily accompanied the police detectives in an unmarked vehicle to search for evidence, that Defendant did not knowingly, intelligently, and voluntarily waive his Miranda rights, and that Defendant's video-recorded statement was inadmissible in accordance with Missouri v. Seibert, 542 U.S. 600 (2004). The Supreme Court vacated the superior court's order, holding (1) one of the statements at issue was admissible in evidence; and (2) remand was required for limited factual determination by the trial justice as to whether the other statement was a knowing, intelligent, and voluntary waiver of Defendant's Fifth Amendment rights. View "State v. Morillo" on Justia Law