Justia Rhode Island Supreme Court Opinion Summaries

The Department of Children, Youth, and Families (DCYF) became involved with A.N.'s family after the Rhode Island State Police informed them that A.N.'s father, Francis N., had been arrested on felony charges, including indecent solicitation of a child and electronically disseminating indecent material to a minor. Following his arrest, DCYF initiated an investigation and found that Francis had admitted to soliciting sex from a fictitious 13-year-old girl online. Consequently, DCYF filed a neglect petition against Francis, alleging that he failed to provide A.N. with proper care and supervision.The Family Court granted DCYF temporary custody of A.N. and later held a permanency hearing, ordering that A.N. remain in DCYF's care. Despite DCYF's efforts to engage Francis in services and case planning, he refused to comply, including declining to submit to a sex offender evaluation. During the neglect petition hearing, Francis invoked his Fifth Amendment right against self-incrimination multiple times when questioned about his criminal charges and his involvement with A.N. The Family Court found by clear and convincing evidence that Francis neglected A.N., citing his failure to provide care, supervision, or guardianship, and his lack of engagement with DCYF.The Rhode Island Supreme Court reviewed the case and affirmed the Family Court's decree. The Supreme Court held that it was proper for the Family Court to draw adverse inferences from Francis's invocation of his Fifth Amendment right in a civil proceeding. The Court found clear and convincing evidence supporting the Family Court's finding of neglect, noting Francis's refusal to engage in necessary services, his lack of financial support for A.N., and his displacement of A.N. from the family home. The Supreme Court concluded that Francis's actions demonstrated a disregard for A.N.'s safety and needs. View "In re A.N." on Justia Law

A fatal motor vehicle accident involving a juvenile driver led to a delinquency petition filed against the driver, who later pleaded nolo contendere to two charges of driving so as to endanger, resulting in death. The parents of the deceased, who were present for the plea, subsequently filed a motion in the Family Court seeking access to the transcript of the proceeding where the juvenile driver was certified and sentenced. The Family Court denied the motion, leading to an appeal by the deceased's parents, who were not parties to the case.The Family Court's denial of the motion was based on the consideration of the "good cause" standard, as stipulated by the statute and precedent. The court found that the parents failed to show how they would not be able to seek restitution for their damages without the transcript. The court also noted that the parents and their attorneys were present during the proceedings for which they requested a transcript. Balancing the interests of the state in protecting the confidentiality of juvenile justice proceedings against the interests of the parents, the court concluded that the state's interests outweighed the parents' interests.The Supreme Court of Rhode Island affirmed the Family Court's order. The Supreme Court noted that the parents failed to meet the standard for production of confidential juvenile records of Family Court proceedings. The court also disagreed with the parents' argument that the transcript might prove helpful in the event of inconsistencies in the juvenile's testimony, describing this argument as speculative. The court concluded that the Family Court did not abuse its discretion in denying the motion. View "In re C.R." on Justia Law

The case involves the Department of Children, Youth, and Families (DCYF) in Rhode Island, which was held in contempt by the Family Court for failing to place a minor, N.B., in a specific facility, St. Mary’s Home for Children, as ordered by the court. N.B., who has behavioral issues and Type I juvenile diabetes, was initially placed in Hasbro Children’s Hospital after her mother refused to take her home due to safety concerns. The Family Court ordered DCYF to place N.B. at St. Mary’s, but the facility refused to admit her due to her medical needs and behavioral issues. Despite DCYF's efforts to secure a placement for N.B., including contacting multiple potential placements and attempting to hire nurses to monitor N.B.'s diabetic care needs, no suitable placement was available.The Family Court found DCYF in contempt for failing to place N.B. at St. Mary’s, rejecting DCYF's argument that it was impossible to comply with the placement order. The court ordered DCYF to pay a daily sanction until it complied with the order. DCYF appealed the contempt order, arguing that the Family Court abused its discretion by finding that DCYF had not exercised reasonable efforts to place N.B. and that it was impossible to comply with the placement order.The Supreme Court of Rhode Island vacated the Family Court’s contempt order. The Supreme Court found that DCYF had made substantial efforts to place N.B. at St. Mary’s and other appropriate facilities, but compliance with the placement order was outside the department’s control due to circumstances such as the refusal of facilities to accept N.B. and ongoing nursing shortages related to the COVID-19 pandemic. The Supreme Court concluded that the Family Court had abused its discretion in finding that DCYF had not used reasonable efforts to place N.B. and in holding DCYF in contempt. View "In re N.B." on Justia Law

The Supreme Court affirmed the judgment of the Family Court finding Respondent, a juvenile, delinquent for committing first-degree robbery and conspiracy to commit robbery.The only pertinent issue Respondent raised on appeal was whether the State met its burden of establishing the corpus delicti of the crimes of robbery and conspiracy to commit robbery such that the trial justice properly admitted Respondent’s confession into evidence. The Supreme Court concluded that the State did establish the corpus delicti of both first-degree robbery and conspiracy to commit robbery, and therefore, the trial justice did not err in admitting Respondent’s confession. View "In re Joseph C." on Justia Law

In 2012, the Cranston Police Department filed delinquency petitions alleging that, when B.H. was 13 years old, he committed two offenses that, if committed by an adult, would constitute the offense of first-degree child molestation and one offense that, if committed by an adult, would constitute the offense of second-degree child molestation. The victims were 11-year-old boys.The Family Court found the B.H. delinquent for the violations under G.L. 1956 11-37-8.1 and 11-37-8.2. The Rhode Island Supreme Court remanded, finding that the evidence at the delinquency proceeding was insufficient to establish sexual penetration—an element of both of the charges of first-degree child molestation of which the respondent was adjudged to be delinquent. The court directed the Family Court to enter adjudications of delinquency on the lesser-included offense of second-degree child molestation sexual assault (second-degree child molestation). View "In the Matter of B.H." on Justia Law

After an adjudication, Respondent was found delinquent for engaging in second-degree child molestation sexual assault. At the conclusion of a sentencing hearing, the family court ordered that Respondent register as a sex offender. Respondent appealed, arguing that legally sufficient evidence did not exist to support the finding that he was delinquent because his actions were motivated by sexual arousal or gratification. The Supreme Court affirmed the adjudication of the family court, holding that there was sufficient evidence to support the trial justice’s finding that Respondent touched the complainant for the purposes of sexual gratification. View "In re Kyle A." on Justia Law

After J.S., a juvenile, injured an individual with a knife, the state police filed two petitions against J.S., including a petition alleging that J.S. was delinquent due to having committed an offense that, if committed by an adult, would constitute an assault with a dangerous weapon. The family court found J.S. delinquent for committing an assault with a dangerous weapon and placed him on probation. The Supreme Court affirmed, holding that there was sufficient legally competent evidence to support (1) the trial justice’s finding that the State presented sufficient evidence to disprove J.S.’s defense of self-defense beyond a reasonable doubt, and (2) the trial justice’s adjudication of Respondent as delinquent for having committed an assault with a dangerous weapon. View "In re J.S." 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