Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of seven counts of simple assault. At the time of the alleged incidents, Defendant was a captain at the Rhode Island Adult Correctional Institutions (ACI). The charges leveled against Defendant related to his treatment of four ACI inmates. The Supreme Court affirmed the judgment of conviction, holding that the trial justice did not commit reversible error when he (1) denied Defendant's motion to sever his trial from that of his co-defendant; (2) granted the prosecution's motion to preclude the testimony of an inmate; (3) denied Defendant's motion for a new trial; (4) instructed the jury; and (5) allowed the prosecution to introduce certain photographs into evidence that were not disclosed during discovery, as the nondisclosure was inadvertent and did not prejudice Defendant. View "State v. Botas" on Justia Law

Plaintiff filed suit against the State alleging statutory claims under the Rhode Island Fair Employment Practices Act, the Rhode Island Civil Rights Act, and the Rhode Island Whistelblowers' Protection Act. The State filed a motion to dismiss and a motion for summary judgment, arguing that the claims should be barred by the doctrine of res judicata because Plaintiff had previously filed a nearly identical suit in federal court, which dismissed the action. The superior court denied the State's motions. The Supreme Court quashed the decision of the superior court and remanded, holding that the federal court judgment was entitled to preclusive effect, and Plaintiff's claims were barred by res judicata. View "Huntley v. State" on Justia Law

Defendant pled nolo contendere to breaking and entering. Over the next several years, the state filed five notices of probation violation against Defendant. The fourth notice of violation, the subject of this appeal, alleged that Defendant had violated R.I. Gen. Laws 11-8-2 by breaking and entering a residence. The sentencing magistrate revoked five years of Defendant's previous suspended sentence and retained eight years of that suspended sentence, with probation. Defendant subsequently filed a motion for modification or reduction of his sentence and a separate motion to vacate his sentence. A sentencing magistrate denied Defendant's motion. The Supreme Court granted in part and denied in part Defendant's appeal, holding (1) because Defendant had been released from prison, the issues that were raised about his admission of probation violation and the length of time that he was required to serve for violation of the conditions of his probation were moot; and (2) the sentencing magistrate erred when she calculated the time that remained on Defendant's suspended sentence and probation. Remanded. View "State v. Isom" on Justia Law

After a jury trial, Defendant was convicted of simple assault and disorderly conduct. The Supreme Court affirmed, holding that the superior court did not commit reversible error in refusing to (1) holding a posttrial evidentiary hearing to determine if the jury was racially biased or if certain juror misconduct had occurred; (2) permit the all fifteen jurors who heard the evidence to be seated on the deliberating panel, as no more than twelve jurors may be seated unless both parties agree; and (3) instruct the jury that aggressive actions of the police could constitute a defense to the charge of disorderly conduct. View "State v. Brown" on Justia Law

The director of the Department of Mental Health, Retardation and Hospitals (Department) petitioned the superior court for an emergency transfer of Irving Briggs, a sentenced inmate, from the forensic unit of the Eleanor Slater Hospital, where Briggs was receiving mental-health services, back to the Adult Correctional Institutions (ACI) where he had previously been incarcerated. The superior court allowed an emergency transfer in the absence of a full evidentiary hearing, finding that potential harm could occur to others if Briggs were to remain at the forensic unit. After a post-transfer evidentiary hearing, a mental health advocate filed a motion to impose sanctions, alleging that the Department contrived a materially inaccurate set of facts to secure an immediate discharge of Briggs from the hospital. The trial justice declined to find a conspiracy among the Department staff and administration to remove Briggs from the forensic unit at any and all costs. The Supreme Court affirmed, holding (1) the trial justice did not abuse his discretion when it denied to impose sanctions; and (2) Briggs's argument that his emergency transfer to the ACI violated his procedural due process rights was moot. View "In re Briggs" on Justia Law

Defendants, the city zoning board of review and the members of that board voted at a February 23, 2009 meeting to approve a request for an extension of time in which to substantially complete certain improvements to property. The request was referenced in one of the items contained in the agenda posted with respect to the board's meeting. Plaintiffs alleged that the agenda item violated the Rhode Island Open Meeting Act because it was a vague and indefinite notice to the public and one lacking in specificity. The superior court granted Defendants' motion for summary judgment, finding that the agenda item provided sufficient notice and thus did not violate the Act. The Supreme Court vacated the judgment of the superior court, holding that the agenda item did not fairly inform the public of the nature of the business to be discussed or acted upon, and thus the agenda item did not comply with the standard established by the Act. Remanded for entry of summary judgment in favor of Plaintiffs with instructions that the action taken by the zoning board be declared null and void. View "Anolik v. Zoning Bd. of Review of City of Newport" on Justia Law

In 2002, Defendant pleaded guilty to several criminal offenses and was sentenced to a term of probation. In 2009, Defendant was adjudged to be in violation of his probation. The superior court subsequently executed six years of Defendant's previously imposed sentence. Defendant appealed, challenging the sufficiency of the evidence in support of the superior court's judgment. The Supreme Court affirmed, holding that the evidence was sufficient to support the hearing justice's finding that Defendant failed to keep the peace or remain on good behavior, and thus, the hearing justice did not rule in an arbitrary or capricious manner in finding that Defendant violated the terms and conditions of his probation. View "State v. Lopes" on Justia Law

After a jury trial, Defendant was convicted of manufacturing or cultivating marijuana. The Supreme Court affirmed the conviction, holding that the trial justice (1) did not err in denying Defendant's motion for a judgment of acquittal as to the charge of manufacturing and cultivating marijuana where the evidence was legally sufficient to support the conviction; (2) did not err in denying Defendant's motion for a judgment of acquittal as to aiding or abetting the manufacture and cultivation of marijuana because the evidence supported that offense; and (3) did not err when he instructed the jury that it could convict Defendant of manufacturing or cultivating marijuana as an aider or abettor. View "State v. Long" on Justia Law

After a jury trial, Defendant was convicted of robbery in the first degree, conspiracy to commit robbery, breaking and entering a dwelling without consent while the owner was on the premises, carrying a firearm without a license, and using a firearm during the commission of a crime of violence. Defendant appealed, arguing that the trial justice erred by admitting into evidence unredacted photographs not only that portrayed his tattoos, but his face as well. The Supreme Court affirmed, holding that the trial justice did not abuse his discretion in determining that the pictures showing Defendant's face were relevant or in admitting the photographs into evidence. View "State v. Delarosa" on Justia Law

After a jury trial, Defendant was convicted of several firearm offenses, eluding a police officer, and resisting arrest. Defendant's convictions were affirmed on appeal. Defendant subsequently filed an application for postconviction relief, claiming that the jury was improperly instructed and that the trial justice erred when he permitted an alcohol, tobacco, firearms, and exposives agent to "offer to the jury an opinion on the truthfulness of a statement" Defendant made. The trial justice dismissed Defendant's application. On appeal, Defendant argued that the agent's testimony was prejudicial and not capable of being cured with a cautionary instruction and that the cautionary instruction was improper. The Supreme Court affirmed, holding that Defendant's claims were barred by res judicata because Defendant failed to raise his claims on direct appeal. View "Hall v. State" on Justia Law