Justia Rhode Island Supreme Court Opinion Summaries

Defendant Roy Diefenderfer was convicted of first-degree robbery, conspiracy to commit robbery, kidnapping, and assault of a person over sixty years of age. Defendant thereafter moved for a reduced sentence, arguing that his sentence be reduced because of, inter alia, his good behavior at the adult correctional institutions and the extreme hardship his family endured during his incarceration. The hearing justice - a different justice from the one who originally sentenced Defendant - denied the motion. The Supreme Court vacated the order of the superior court, holding that the hearing justice applied an incorrect standard in denying Defendant's sentence-reduction motion, as, specifically, the justice erroneously applied the appellate standard of review. View "State v. Diefenderfer" on Justia Law

A jury convicted Defendant Ronald Barkmeyer of first-degree child molestation. The trial justice sentenced Defendant to fifty years incarceration, with thirty years to serve and the remaining twenty years suspended, with probation. Thereafter, Defendant moved for a reduced sentence. The superior court denied the motion. The Supreme Court affirmed the order of the superior court, holding that the trial justice (1) did not abuse his discretion in failing to afford much, if any, weight to defendant's prison behavior or rehabilitative efforts, and (2) properly exercised his discretion in not bestowing upon Defendant the leniency he requested and confirming Defendant's sentence. View "State v. Barkmeyer" on Justia Law

When he was fifteen years old, Craig Price admitted committing four brutal murders. Price was committed to the custody of a training school, and the family court directed the school to provide intensive psychiatric treatment for Price. Later, Craig Price was convicted of criminal contempt for refusing to cooperate in psychiatric treatment, after previously having been adjudicated to be in civil contempt for the same offense. Price was sentenced by the family court to twenty-five years at the adult correctional institutions, with ten years to serve and the balance suspended, with probation. The Supreme Court affirmed. Price subsequently filed an application for postconviction relief, which the family court denied. The Supreme Court affirmed, holding (1) res judicata barred the Court from considering Price's double jeopardy claim; (2) because Price's double jeopardy claim had no merit, Price's counsel was not ineffective by failing to raise it; (3) the trial justice acted within his discretion in imposing the sentence, and the sentence was not excessive; and (4) Price's claim that he was denied due process because he was declared a violator and ordered to serve a portion of the suspended sentence, which had not yet begun, was barred by res judicata. View "Price v. Wall" on Justia Law

When Neighborhood Health Plan of Rhode Island (NHP), a not-for-profit corporation that operated a licensed health maintenance organization that provided health insurance coverage to its enrollees, began reimbursing ophthalmologists at a higher rate than the rate paid to optometrists for performing the same services, two optometrists brought an action on behalf of all optometrists who had entered into participating provider agreements with NHP during the period that the differential reimbursement policy was in effect, contending that this differential reimbursement violated state law. The superior court granted summary judgment in favor of NHP, reasoning that the antidiscrimination provision in R.I. Gen. Laws 5-35-21.1(b) applied only to expenditures of public funds and that NHP did not violate the statute because NHP paid for the ophthalmologists' services using private money. The Supreme Court affirmed, holding (1) the statute at issue was not ambiguous; and (2) the motion justice did not err in concluding that NHP is not an agency or department of the state and cannot otherwise be considered a state actor. View "Drs. Pass and Bertherman, Inc. v. Neighborhood Health Plan of R.I." on Justia Law

After a jury trial, Applicant Theodore Chapdelaine was found guilty of second-degree child molestation. Defendant later filed an application for postconviction relief, alleging ineffective assistance of his trial defense counsel. The trial justice denied Applicant's application, finding his claims to be without merit. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not err in denying the motion where (1) counsel's conduct during plea negotiations was not so deficient as to constitute ineffective assistance of counsel; (2) Applicant affirmatively waived any claim of error arising out of an alleged conflict of interest; (3) counsel's strategy of excluding any mention of drug or alcohol use at the trial to protect Applicant constituted professionally reasonable judgment; and (4) counsel's representation was not ineffective because he failed to explore the use of expert testimony to establish the significance of Applicant's possible psychological issues. View "Chapdelaine v. State" on Justia Law

After a jury trial, Gerald Brown was convicted of sexual assault and child molestation. The superior court dismissed his second application for postconviction relief. The Supreme Court affirmed, holding that the hearing justice (1) properly concluded that Brown's application could be summarily decided without an evidentiary hearing after providing Brown sufficient opportunity to respond to the proposed dismissal of his application; (2) appropriately deemed Brown's claim of newly discovered evidence as waived; (3) properly dismissed Brown's claim of unlawful incarceration; and (4) correctly dismissed Brown's assertions of ineffective assistance of counsel based on prior counsels' failure to raise a statute-of-limitations defense. View "Brown v. State" on Justia Law

Defendant was convicted of domestic first-degree sexual assault and domestic assault with intent to commit sexual assault. The Supreme Court affirmed, holding that the trial justice did not abuse her discretion by (1) refusing to pass the case after the complainant testified that the police issued to her a no-contact order against Defendant because (i) the testimony was not sufficiently prejudicial as to prevent the jury from calmly and dispassionately considering the evidence, (ii) the trial justice's cautionary instructions alleviated any prejudicial impact of the testimony, and (iii) the jury's final verdict suggested that the testimony did not inflame the passions of the jurors to the point where they were unable to pass impartially upon the issues in the case; and (2) denying a second motion to pass the case when a police officer, while testifying, improperly bolstered the complainant's credibility because the improper bolstering was not sufficiently prejudicial to Defendant. View "State v. Rushlow" on Justia Law

Police officers applied for and obtained a search warrant for Defendant Edward Gordon's apartment after a woman reported that Defendant had sexually assaulted her. A jury convicted Defendant of second-degree sexual assault and deadlocked on Defendant's kidnapping charge. Defendant appealed, arguing (1) the superior court magistrate had no authority issue the search warrant, and (2) retrial on the charge of kidnapping would violate his rights with respect to the double-jeopardy provisions of the state and federal Constitutions. The Supreme Court affirmed, holding (1) the magistrate had the authority to issue the search warrant, and (2) the trial justice did not abuse his discretion when he determined that the jury was genuinely deadlocked, and therefore, retrial on the charge of kidnapping did not violate double jeopardy. View "State v. Gordon" on Justia Law

Defendant Windell McRae was convicted for simple domestic assault. Defendant appealed, arguing, inter alia, that a remark by complainant that Defendant had been drinking on the day of the assault was sufficiently prejudicial as to prevent the jury from calmly and dispassionately considering the evidence. The Supreme Court affirmed the superior court, holding (1) considering the full testimonial evidence and the trial justice's specific and cautionary instruction to the jury, the trial justice did not clearly err by denying Defendant's motion to pass the case after the complainant testified about Defendant's drinking; and (2) the trial justice did not abuse his discretion in admitting, for impeachment purposes, evidence of Defendant's prior convictions. View "State v. McRae" on Justia Law

Twelve-year old Frances G. told a law enforcement officer that she threw a rock or brick against the windshield of a vehicle and carved something into the side of the vehicle. After a trial before a justice of the family court, Frances was adjudicated to be wayward. The Supreme Court affirmed, holding (1) the trial justice was not clearly wrong when she allowed the vehicle's owner to testify about what her daughter told her she saw Frances do to the car because the statement qualified as an "excited utterance" under R.I. R. Evid. 803(2); and (2) Frances knowingly and voluntarily waived her Miranda rights before speaking to the law enforcement officer, and therefore, the trial justice did not err in admitting the statement into evidence. View "In re Frances G." on Justia Law