Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, defendant Tracey Barros was convicted of conspiracy to commit murder, first-degree murder, discharging a firearm while committing a crime of violence, and unlawfully carrying a firearm without a license. On appeal, Defendant contended that the trial justice erred when he (1) denied Defendant's motion to suppress his confession, and (2) precluded cross-examination of a prosecution witness with respect to purported third-party-perpetrator evidence. The Supreme Court affirmed, holding (1) the trial justice did not err in denying Defendant's motion to suppress as a review of the record revealed that Defendant's statements were voluntary and the timing of Defendant's presentment was not operative in inducing him to make his confession; and (2) the trial justice did not err in granting the prosecution's motion in limine to preclude the admission of third-party-perpetrator evidence because Defendant did not offer evidence reasonably specific to establish (a) that the individuals referred to had an opportunity to commit the crime or (b) a proximate connection between the individuals and the victim. View "State v. Barros" on Justia Law

Appellant Craig Quigley was a beneficiary of a testamentary trust. In 2003, the trustees filed a petition in the superior court to reform the trust. The court entered an order granting the petition. In 2009, Quigley filed a motion to vacate the order, arguing (1) that the superior court had never obtained jurisdiction over Quigley because there was no service of process with respect to the petition and, therefore, any judgment against Quigley was void; and (2) the order should be vacated pursuant to R.I. Sup. Ct. R. 60(b)(6), which provides for vacation of any order for "any other reason justifying relief." The hearing justice denied the motion. Quigley appealed. The Supreme Court affirmed, holding (1) because Quigley was not a defendant in the proceeding with respect to the petition for reformation of the trust, service of process was not required; (2) because Quigley had actual notice of the proceeding and was represented by counsel at the proceeding, Quigley's due process rights were not violated; and (3) the Rule 60(b)(6) motion was not made within a reasonable time in violation of the rule. View "In re Will of Quigley" on Justia Law

Defendant James Enos dated Mary for six months before they separated. After their separation they met at a restaurant where defendant began swearing at Mary. Defendant then hit Mary on the head with drinking glasses and kicked her. Defendant was convicted of domestic assault with a dangerous weapon. Defendant appealed, arguing (1) that the evidence presented by the state was legally insufficient for a reasonable juror to conclude that defendant and Mary were in a domestic relationship; and (2) the trial justice erred when she refused to declare a mistrial after a police officer testified that after defendant was informed of his Miranda rights defendant remained silent. The Supreme Court affirmed, holding (1) the evidence, overall, indicated that defendant and Mary were in a substantive dating relationship and therefore the trial justice correctly denied defendant's motion for a judgment of acquittal; and (2) the trial justice was not clearly wrong when she denied the defendant's motion for a mistrial and instead opted to instruct the jury to disregard the officer's unsolicited remark. View "State v. Enos" on Justia Law

Plaintiff Kathy Lamarque executed a mortgage with defendant Centreville Savings Bank. After defaulting on another loan for a second mortgage on the same property, defendant disclosed the balance of plaintiff's mortgage to the purchaser of plaintiff's property at a foreclosure sale. Plaintiff filed a complaint against defendant for negligence and a violation of plaintiff's privacy rights. At trial, defendant moved for a judgment on partial findings, which the trial court granted. Plaintiff appealed, arguing that her right to privacy was violated by defendant and that the Gramm-Leach-Bliley Act and defendant's privacy policy created a legal duty to protect private information from disclosure. The Supreme Court affirmed, holding that under the facts of the case, plaintiff's privacy rights were not violated and defendant did not breach its duty to plaintiff. View "Lamarque v. Centreville Savings Bank" on Justia Law

In 2006, defendant Edgar Goulet killed his dog by shooting it with a sawed-off shotgun. One year later, the state, by way of criminal information, charged defendant with one count of malicious killing of an animal and one count of possession of a sawed-off shotgun. At trial, among other motions, defendant filed a motion to sever to the two counts of the information. The motion to sever was denied. After a jury trial defendant was convicted on both counts. The defendant appealed. The issues properly before the Supreme Court were (1) defendant's assertion that the trial justice erred when he denied defendant's motion to sever, and (2) the defendant's Fourth Amendment claims relating to the police officers' searches of the defendant's yard and home. The Court affirmed, concluding (1) the defendant did not make a sufficient showing that he would be prejudiced to the extent that he would not receive a fair trial if the two counts were not severed, and thus the trial justice did not abuse his discretion when he denied defendant's motion; and (2) the defendant's Fourth Amendment claims as to the propriety of the warrantless search were without merit. View "State v. Goulet" on Justia Law

Plaintiff Horton appealed from a superior court grant of summary judgment in favor of the police department defendants, dismissing the plaintiff's thirteen-count complaint which alleged, among other complaints, malicious prosecution, false arrest, false imprisonment, tortious denial of access to public records, violations of civil rights, and failure to destroy records after exoneration. The Supreme Court affirmed, holding (1) defendants possessed probable cause for each instance of prosecution, arrest, and imprisonment, making a grant of summary judgment appropriate; and (2) because Horton failed to provide analysis of the remaining questions in his appeal, those contentions were deemed waived for appellate review. View "Duane Horton v. Portsmouth Police Dep't, et al." on Justia Law

The issue for review by the Supreme Court was whether the Town of North Providence complied with the Rhode Island Zoning Enabling Act of 1991 when it amended the town's zoning ordinance in 1999. The zoning law in question dealt with the notice and hearing requirements for the adoption, repeal, and amendment of zoning ordinances. Plaintiff Generation Realty, LLC and several others owned or were prospective purchasers of land in North Providence. They brought suit against Defendants Kristen Catanzaro and other town officials, alleging that the town did not provide adequate notice of a public hearing on the 1999 amendments. Plaintiffs asserted that lack of such notice rendered the amendments null and void. The court ruled in favor of Plaintiffs. Upon review, the Supreme Court found that the ordinance at issue in this case was a "general amendment" under the Act, and as such, required only a public notice. The Court found that the lower court erred in deciding that the ordinance was specific, and therefore erred in ruling in favor of Plaintiffs. The Court remanded the case for further proceedings.

Defendant Memeh Kizekai appealed the conviction and sentence he received for "uttering and publishing" when he and co-Defendant Sonnah Sampson tried to cash a $7500 counterfeit check at a Pawtucket bank. Defendant argued that he should have received a new trial because the evidence presented against him was not credible or sufficient to support his conviction. Defendant and the State agreed that the case turned on whose testimony was more credible: Sampson's or Defendant's. The trial court acknowledged its role as "the 13th juror," and held that its determination was based on "whether or not the evidence placed before the court was sufficient to substantiate and sustain the verdict that the jury achieved." The Supreme Court concluded that the trial court "did not shirk his super juror duties." The Court affirmed the lower court's decision.

Defendant Jose Torres appealed the denial of his motion for post conviction relief. On appeal to the Supreme Court, Defendant argued that the grand jury indictment wrongly charged him with murder. Although he ultimately pled to a lesser charge of manslaughter, Defendant contended that his conviction should be vacated because of an "inherently flawed indictment"--a defect not waived by his plea agreement. "[B]y voluntarily pleading guilty to a charge that was amended with his consent, [Defendant] waived any argument that the State could not have proven him guilty of murder." The Court affirmed the lower court's decision.

Defendant Gerald Lynch appealed his conviction and sentence on four counts of first-degree sexual assault. At trial after the close of evidence, the state dismissed two counts of Defendantâs indictment, and Defendant moved for an acquittal on the remaining counts. The trial judge waited for the jury to return its verdict before ruling on Defendantâs motion. The jury found Defendant guilty on four counts of sexual assault. The judge then denied Defendantâs motion. On appeal, defendant alleged that, among other things, the trial judge erred in denying his motion for acquittal because the state failed to prove its case against him. The Supreme Court found that the evidence presented at trial was sufficient to allow the jury to reach its conclusions and verdict. Finding no error, the Court affirmed the lower courtâs decision.