Justia Rhode Island Supreme Court Opinion Summaries

In the town of Tiverton, two police officers from the Little Compton police department had a discussion with Defendant about a motor-vehicle accident that occurred in Little Compton. The officers then transported Defendant in a police cruiser back to the scene of the accident, where they administered field-sobriety tests, which Defendant failed. Defendant was subsequently charged with driving under the influence of liquor or drugs, among other offenses. Defendant filed a motion to dismiss due to an unlawful arrest, arguing that the officers lacked the authority to arrest him in Tiverton. The trial judge concluded that the arrest was unlawful and dismissed the case. The Supreme Court quashed the judgment of the district court, holding that Defendant was not arrested by the Little Compton police while they were in Tiverton, and therefore, the trial judge erred when she granted Defendant’s motion to dismiss. Remanded.View "State ex rel. Town of Little Compton v. Simmons" on Justia Law

Plaintiffs entered into a loan agreement with Potomac Realty Capital LLC (PRC) to rehabilitate and renovate certain property. As security for the loan, NV One granted a mortgage on the property. Plaintiffs later filed a complaint against PRC, asserting violations of the Rhode Island usury law, among other claims. The trial justice granted summary judgment to Plaintiffs with respect to the usury claim, entered an order declaring the loan usurious and void, and voided the mortgage. At issue on appeal was whether a usury savings clause in the loan document validated the otherwise usurious contract. The Supreme Court affirmed, holding that Plaintiffs were entitled to judgment as a matter of law on their usury claim because (1) the loan was a usury; and (2) the usury savings clause was unenforceable on public policy grounds.View "NV One, LLC v. Potomac Realty Capital, LLC" on Justia Law

Defendant was charged with one count of second-degree sexual assault. A jury trial commenced, but the trial justice granted Defendant’s motion for a mistrial due to a discovery violation. Thereafter, Defendant moved to dismiss the sexual-assault charge on double jeopardy grounds because of prosecutorial goading. The trial justice denied Defendant’s motion. The Supreme Court upheld the trial justice’s denial of Defendant’s motion to dismiss the charge, holding that sufficient evidence in the record supported the trial justice’s finding that the objective facts did not give rise to an inference of intentional goading.View " State v. Rolle" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree child molestation sexual assault. Defendant appealed, contending, among other things, that the trial justice erred when it denied his motion to suppress statements made to police during a post-arrest interrogation. The Supreme Court (1) affirmed the trial justice’s denial of Defendant’s motion for a new trial and discerned no error arising from the justice’s evidentiary rulings; but (2) remanded the case to the superior court with directions to make additional findings of fact and credibility determinations concerning the voluntariness of Defendant’s confessions, as the trial justice failed to make the findings of fact and credibility determinations essential to support his ultimate finding of voluntariness. View "State v. Bojang" on Justia Law

At issue in this case was the Casino Acts, two pieces of legislation providing for the establishment of state-authorized table games at gambling facilities at which Plaintiff, the Narragansett Indian Tribe, received a percentage of income from authorized video lottery terminal (VLT) machines. Plaintiff filed a complaint seeking a declaration that that the Casino Acts were unconstitutional. The superior court concluded that Plaintiff had standing but that Plaintiff failed to meet its burden of proving that the Casino Acts violated the Constitution. Plaintiff appealed, and the State cross-appealed as to the issue of standing. The Supreme Court declined to consolidate the two appeals, and therefore, only the State’s appeal on the issue of standing was before the Court. The Court then affirmed the judgment of the superior court finding that the Tribe was entitled to bring its claims challenging the Casino Act, holding that the reasonable likelihood that the Tribe would suffer a reduction in income from the removal of VLT machines due to the establishment of the table games was sufficient to support a finding that the Tribe had suffered an injury in fact. View "Narragansett Indian Tribe v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of assault with a dangerous weapon and one count of simple assault. On appeal, Defendant argued, among other things, that the prosecutor improperly vouched for the credibility of two witnesses during her closing argument. The Supreme Court affirmed the convictions, holding (1) the trial justice did not abuse his discretion by allowing the state to impeach Defendant’s credibility with his fourteen prior criminal convictions; and (2) although a portion of the prosecutor’s closing argument was akin to vouching, the trial justice did not err by refusing to pass the case. View "State v. Whitfield" on Justia Law

After a jury trial, Defendant was found guilty of two counts of second-degree child molestation sexual assault. The Supreme Court affirmed the superior court’s judgment of conviction and its denial of Defendant’s motion for a new trial, holding (1) the trial justice did not abuse his discretion in denying Defendant’s motion to pass the case after the prosecutor engaged in an improper line of questioning to a witness, as any prejudice which may have resulted was cured by the trial justice’s instruction to the jury; and (2) the trial justice did not misconceive or overlook material testimony and did not otherwise commit clear error in denying Defendant’s motion for a new trial. View "State v. Hie" on Justia Law

In 1990, Applicant was convicted of one count of first-degree sexual assault. In 2001, Applicant filed a pro se application for postconviction relief, alleging ineffective assistance of counsel and trial error. In 2005, the hearing justice denied the application. The Supreme Court affirmed, holding that the hearing justice properly did not commit clear error or misconceive material evidence in rendering his decision, as (1) Applicant’s claims relating to alleged errors committed by the trial justice were barred by the doctrine of res judicata; and (2) Applicant failed to show to his trial counsel’s representation fell below an objective standard of reasonableness. View "Lamoureux v. State" on Justia Law

Defendant pled nolo contendere to three counts of second-degree child molestation. Before he was sentenced, Defendant filed a motion to withdraw his plea. The trial justice denied the motion and sentenced Defendant to three concurrent sentences of fifteen years at the Adult Correctional Institutions. Eighteen months after sentencing, Defendant filed a motion to vacate judgment and sentence, arguing that his plea to the criminal charges should be set aside because his attorney did not inform him that the attorney was undergoing personal struggles during his representation of Defendant. The Supreme Court affirmed, holding (1) Defendant's appeal was not properly before the court; and (2) even if Defendant's argument was properly made, the argument was without merit.View "State v. Castriotta" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree child molestation and one count of second-degree child molestation. The Supreme Court affirmed the convictions on direct appeal. Appellant subsequently filed an application for postconviction relief, arguing that his trial counsel provided ineffective assistance. The trial justice denied the application, concluding that Appellant failed to establish that his counsel’s performance was deficient. The Supreme Court affirmed, holding that the trial justice did not err in finding that trial counsel performed at a high level and in thus denying Appellant’s application for postconviction relief. View "Merida v. State" on Justia Law