Justia Rhode Island Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
State v. Robinson
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
Estrella v. Janney Montgomery Scott LLC
The Supreme Court affirmed in part and vacated in part the amended judgment of the superior court in favor of Plaintiff, as executor of the Estate of Armando Damiani (Mandy) and the Estate of Lillian Estrella, in this action alleging that Defendants had conspired to commit an unlawful conversion of funds in Mandy's investment account, holding that the portion of the amended judgment awarding Plaintiff compensatory damages and prejudgment interest was error.Specifically, the Supreme Court held (1) the trial justice erred by permitting a witness to testify despite knowing that she would invoke her privilege against self-incrimination under the Fifth Amendment, and the error prejudiced Defendant; and (2) there was no reason to disturb the trial justice's decision on Plaintiff's claim for declaratory judgment. View "Estrella v. Janney Montgomery Scott LLC" on Justia Law
State v. Sinapi
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
Felkner v. R.I. College
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
State v. Delossantos
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
State v. Morillo
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
State v. Jimenez
The Supreme Court affirmed the judgment of the superior court convicting and committing Defendant for one count of second-degree murder and one count of first-degree child abuse, holding that there was no prejudicial error in this case.Specifically, the Supreme Court held that the trial justice (1) did not err in denying Defendant's motion to suppress the statement he made while at the police station after concluding that Defendant was not seized without probable cause prior to giving his statement; (2) did not err in denying Defendant's motion to dismiss all counts of the indictment as unconstitutionally vague; and (3) did not overlook or misconceive material evidence in denying Defendant's motion for new trial. View "State v. Jimenez" on Justia Law
Riley v. Narragansett Pension Board
The Supreme Court vacated in part the judgment of the superior court reversing the decision of the Board to revoke Plaintiff's pension, ordering the permanent reinstatement of the pension, and declaring the pension revocation ordinance of the Town of Narragansett to be unconstitutionally vague, holding that the Board failed to make findings of fact or conclusions of law to support its decision.Plaintiff was a police officer with the Narragansett Police Department for twenty-eight years prior to his retirement. After Plaintiff pled guilty to transferring obscene matter to a person under the age of sixteen years the Board voted to revoke his pension under the pension revocation ordinance. Plaintiff and his wife sued. The trial justice concluded that the Board had violated Plaintiffs' due process rights in several respects and erred in declaring the pension revocation ordinance to be unconstitutionally vague. The Supreme Court vacated the judgment in part and remanded the case, holding that the trial court failed to make competent factual findings on which to base an as-applied analysis of the constitutionality of the pension revocation ordinance. View "Riley v. Narragansett Pension Board" on Justia Law
State v. Corcoran
The Supreme Court affirmed the order of the superior court granting Defendant's motion to suppress the statements he made to police at the scene of an automobile collision, holding that the superior court did not abuse its discretion in granting the suppression motion.Specifically, the Supreme Court held (1) the trial justice correctly determined that Defendant was in custody when he made incriminating statements to the law enforcement officer at the scene of the arrest and therefore correctly suppressed the statements Defendant made to the officers at the time; and (2) the state's second contention on appeal was not properly before the Court. View "State v. Corcoran" on Justia Law
State v. McGuire
The Supreme Court affirmed the order of the superior court granting Defendants' motion to dismiss all electronic, wire, or oral communications obtained through the use of wiretaps and any subsequently-obtained evidence in these consolidated cases, holding that the trial justice did not err.In granting Defendants' motion to suppress, the trial justice found that an associate justice of the superior court had no authority to issue the wiretap orders. The State appealed this ruling and argued, alternatively, that the trial justice erred in concluding that suppression of the evidence derived from the wiretap orders was warranted. The Supreme Court affirmed, holding that the trial court correctly concluded that the associate justice was not vested with the statutory authority to administer and sign the wiretap orders and, therefore, that those orders were in violation of R.I. Gen. Laws 12-5.1, the Interception of Wire and Oral Communications Act. View "State v. McGuire" on Justia Law