Justia Rhode Island Supreme Court Opinion Summaries

The Providence Journal Company and Amanda Milkovits (collectively, the Journal) requested records from the Rhode Island State Police concerning an investigation of an underage drinking incident at property owned by the then-Governor Lincoln Chafee. The Rhode Island Department of Public Safety Department denied the Journal’s records request. Thereafter, the Journal filed a complaint against the Department, the State Police, and the Commissioner of the Department (collectively, Defendants) alleging violations of Rhode Island’s Access to Public Records Act (APRA). The superior court granted summary judgment to Defendants, concluding that the requested documents were not subject to public disclosure pursuant to the APRA. The Supreme Court affirmed, holding that the records request was properly denied pursuant to the APRA. View "Providence Journal Co. v. R.I. Dep’t of Pub. Safety" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and related crimes. Defendant appealed, arguing that the trial justice erred in (1) failing to grant his motion to suppress evidence that was obtained as a result of his warrantless arrest in his home, and (2) failing to remove two allegedly biased jurors from the jury or, in the alternative, to grant a mistrial. The Supreme Court vacated the judgment of the superior court and remanded for a new trial, holding (1) the trial justice erred in denying Defendant’s motion to suppress, as the warrantless entry into Defendant’s home was not consented to freely and voluntarily, and the State failed to establish the existence of exigent circumstances to justify the entry into the home; and (2) the error in this case was not harmless. Remanded for a new trial. View "State v. Gonzalez" on Justia Law

The Rhode Island Department of Transportation (RIDOT) condemned a parcel of real property owned by Richard Deeble and his wife for highway purposes. The Deebles subsequently died. RIDOT utilized only a portion of the condemned property in furtherance of the relocation of an interstate. Plaintiff, the Estate of Richard Deeble, sought declaratory and injunctive relief against RIDOT, asserting that should RIDOT seek to sell or lease the condemned property, the Estate was entitled to a right of first refusal to repurchase or lease the land in accordance with article 6, section 19 of the Rhode Island Constitution. The superior court justice concluded that the provisions of article 6, section 19 did not pass to the Estate. The Supreme Court affirmed, holding that the rights guaranteed by article 6, section 19 terminate upon the death of the original condemnee. View "Estate of Richard J. Deeble v. Dep’t of Transp." on Justia Law

After a jury trial, Appellant was convicted of conspiracy to commit assault with a dangerous weapon and assault with a dangerous weapon. Appellant was also charged with first-degree murder, but the jury was unable to reach a verdict on that charge. After a second jury trial, Appellant was convicted of one count of first-degree murder. Appellant later filed an application for postconviction relief, arguing that his second trial was not fair because the justice who presided over that trial had previously represented Appellant in family court when Appellant was a minor. Appellant also alleged that his counsel at the second murder trial was ineffective. After a hearing, the hearing justice denied postconviction relief. The Supreme Court affirmed, holding (1) the hearing justice did not err in denying postconviction relief on the grounds that the trial justice at Appellant’s second murder trial should have recused; and (2) Appellant’s counsel did not provide ineffective assistance at Appellant’s second murder trial. View "Perry v. State" on Justia Law

After a jury trial, Defendant was convicted of one count of felony domestic assault, two counts of assault with a dangerous weapon, and one count of simple domestic assault after previously having been convicted twice of domestic assault. The Supreme Court affirmed. Defendant later filed an application for postconviction relief, alleging that his trial counsel was ineffective because he stipulated to the fact that Defendant had two prior convictions for domestic violence in the presence of the jury. The Supreme Court affirmed, holding that trial counsel’s performance was not deficient, and even if Defendant were able to establish that his trial counsel was ineffective, Defendant’s right to a fair trial was not prejudiced by his trial counsel’s conduct. View "Snell v. State" on Justia Law

A criminal complaint was filed against Defendant charging him with burglary. After a combined bail and violation hearing, a hearing justice found that Defendant failed to be of good behavior and that Defendant violated the terms of his violation. Defendant appealed, arguing, inter alia, that evidence obtained from the search of a vehicle should have been suppressed because it was obtained from an illegal search and seizure. The Supreme Court affirmed, holding (1) Defendant lacked standing to contest the legality of the search of the vehicle; (2) even assuming the police illegally obtained the evidence, the exclusionary rule did not apply at Defendant’s probation revocation hearing; and (3) the hearing justice did not act arbitrarily or capriciously in finding that Defendant violated his probation. View "State v. Ditren" on Justia Law

The issue in these consolidated cases was the passing of the Financial Stability Act and the appointment of a Receiver for the City of Central Falls. The Supreme Court already held that the Act is constitutional, and the issues now before the Court on appeal dealt with the superior court’s holdings that (1) the Central Falls Receiver was entitled to reimbursement of his attorney’s fees; (2) the Central Falls Mayor was not entitled to indemnification from the Receiver for costs and expenses arising out of the instant cases; and (3) denied advance attorney’s fees filed by Attorney Lawrence Goldberg. The Supreme Court reversed the superior court’s judgment in all respects, holding (1) in granting the Receiver reimbursement of its attorneys’ fees, the hearing justice misapplied R.I. Gen. Stat. 45-9-11; (2) the hearing justice erred in concluding that the Mayor was not acting in his official capacity when he challenged the constitutionality of the Act and when he defended himself in the action filed by the Receiver and therefore was not entitled to indemnification for his legal costs; and (3) because Attorney Goldberg was properly retained by the City Council for Central Falls to represent it in the suit regarding the constitutionality of the Act, the attorney was entitled to remuneration. View "Shine v. Moreau" on Justia Law

In 2011, the Town of Middletown issued an invitation for bids on a drainage improvement project. Two contractors submitted bids, including HK&S Construction Holding Corp., which provided the lowest bid. Woodard & Curran, Inc. recommended against awarding HK&S the project and in favor of negotiating a contract with the second bidder. The town counsel concluded that HK&S’s bid was non-responsive and awarded the contract to the second bidder. Plaintiff filed a complaint against the Town and Woodard & Curran alleging, among other claims, that the Town violated state and local law when it denied the contract award for the project. The superior court granted summary judgment for Defendants. The Supreme Court affirmed, holding (1) there was no error in disposing of HK&S’s claims against the Town in summary judgment where HK&S failed to submit a responsive bid; and (2) HK&S’s claim of negligence against Woodard & Curran also failed. View "HK&S Constr. Holding Corp. v. Dible" on Justia Law

After a jury trial, Defendant was found guilty of disorderly conduct and sentenced to six months’ incarceration. The Supreme Court affirmed the judgment of conviction and the denial of Defendant’s motion for a new trial and motion for a judgment of acquittal, holding (1) the trial justice did not err in denying Defendant’s motion for a new trial, as his speech rose to the level of the criminal offense with which he was charged; (2) there was sufficient evidence to convict Defendant; and (3) Defendant’s argument that the criminal complaint lodged against him was insufficient as a matter of law to place him on notice of the charge against him was not properly preserved for appellate review. View "State v. Matthews" on Justia Law

The Narragansett Indian Tribe (Tribe) filed a complaint against the State seeking a declaration that the Casino Act must be invalidated because it is unconstitutionally vague or because it otherwise violates the non-delegation doctrine enunciated in R.I. Const. art. VI, 1 and 2. UTGR, Inc. subsequently intervened as a defendant. The superior court found in favor of Defendants, concluding that the Casino Act was not facially unconstitutional. The Supreme Court affirmed, holding that, based on the strong presumption of constitutionality and the heavy burden of mounting a facial challenge, it could not be said that the Casino Act is facially unconstitutional. View "Narragansett Indian Tribe v. State" on Justia Law