Justia Rhode Island Supreme Court Opinion Summaries

Defendant was convicted of one count of first-degree child molestation sexual assault and four counts of second-degree child molestation assault. Defendant subsequently filed an application for postconviction relief, alleging, inter alia, that his counsel committed prejudicial error when he provided Defendant's confidential psychiatric records to the state without Defendant's knowledge or consent. The superior court denied the application. The Supreme Court affirmed, holding (1) the disclosure and use of the psychiatric records was not enough to prejudice Defendant to the extent of undermining confidence in the outcome of the case; and (2) the postconviction relief justice did not err in concluding that trial counsel was not ineffective to a constitutional dimension for other alleged deficiencies. View "Hazard v. State" on Justia Law

After a jury trial, Defendant was convicted of multiple counts of first-degree sexual assault and second-degree sexual assault and one count of simple assault for his assault against three developmentally disabled women. The cumulative result of Defendant's sentences was life imprisonment followed by a consecutive term of sixteen years to serve. Defendant subsequently filed a motion to reduce his sentence, arguing that the sentence was disproportionate and excessive. The trial court denied Defendant's motion, explaining that the fact that each of the victims in this case was developmentally disabled was the driving force behind the sentence imposed. The Supreme Court affirmed, holding that the trial justice did not abuse his discretion in imposing this sentence and denying Defendant's motion to reduce. View "State v. Rivera" on Justia Law

Defendant entered a plea of nolo contendere to one felony count of possession of a controlled substance. Defendant complied with her conditions of probation. Defendant was subsequently charged with two misdemeanor offenses, both of which were dismissed. Defendant moved to have the records related to the two misdemeanor charges sealed and to have the law-enforcement-identification records related to those charges destroyed. The district court denied the motion, concluding that a nolo plea, followed by a sentence of probation, is considered a conviction for the purposes of the expungement statute. Defendant appealed, arguing that she was not convicted of a felony as defined by R.I. Gen. Laws 12-18-3. The Supreme Court quashed the decision of the district court, holding that, for purposes of the sealing statute, Defendant was not convicted of a felony, she met all the statutory requirements of the sealing statutes, and she was entitled to the benefits provided in those enactments. View "State v. Poulin" on Justia Law

After a jury trial, Defendant was convicted of one count of child enticement. Defendant subsequently filed a motion for a new trial, arguing that there was insufficient evidence to support a conviction on the count of child enticement. The trial justice denied the motion. Defendant subsequently filed a second motion for a new trial based on a claim of newly discovered evidence, which the trial justice also denied. At the conclusion of the hearing on Defendant's second motion for a new trial, the trial judge adjudged Defendant in contempt of court. The Supreme Court affirmed the judgment of conviction as well as the adjudication of contempt, holding (1) Defendant waived the opportunity to argue the insufficiency of the evidence before the Court; (2) the trial justice did not overlook or misconceive material evidence, nor was he otherwise clearly wrong in denying Defendant's second motion for a new trial; and (3) the trial justice did not err in summarily adjudicating Defendant in contempt. View "State v. Price" on Justia Law

After a jury trial, Defendant was convicted of carrying a firearm in a motor vehicle without a license. Defendant appealed, arguing that the trial justice erred (1) when he denied Defendant's motion to suppress a revolver and bullets that Defendant alleged were illegally seized, and (2) in denying Defendant's motion of acquittal. The Supreme Court affirmed, holding (1) the search that led to the seizure of the contested evidence was constitutionally valid, and therefore, the trial justice did not err in denying Defendant's motion to suppress; and (2) there was sufficient evidence to uphold Defendant's conviction, and therefore, the trial justice did not err when he denied Defendant's motion for a judgment of acquittal. View "State v. Santos" on Justia Law

This case involved a dispute between the R.I. Department of Corrections (DOC) and the certified bargaining unit for correctional officers and other DOC employees (the union). The dispute arose from the DOC's proposal to modify the weapons qualification component of the training program for correctional officers. The union filed a grievance, arguing that the training program could not modified without the approval of a training committee that had been created under the parties' collective bargaining agreement (CBA). An arbitrator ruled in the union's favor. The superior confirmed the arbitration award. The Supreme Court affirmed, holding (1) this dispute was arbitrable; and (2) the arbitration award must stand because the arbitrator's interpretation of the CBA was passably plausible, did not reflect a manifest disregard for the law, and was not irrational. View "State Dep't of Corr. v. R.I. Brotherhood of Corr. Officers" on Justia Law

This litigation stemmed from a dispute over monies allegedly owed to a now-defunct corporation for work performed as part of a construction project that took place in 1990. Plaintiff corporation instituted suit about twenty-two years ago. Seventeen years later, the superior court dismissed the action, finding that Plaintiff could neither maintain the action in its own name nor substitute another entity as Plaintiff. The Supreme Court affirmed, holding that, as a defunct corporation, Plaintiff could no longer maintain this action in its own name, and because the receiver was discharged when Plaintiff was dissolved, the receiver could not maintain the action on its behalf. View "Piccoli & Sons, Inc. v. E & C Constr. Co., Inc." on Justia Law

Defendant was charged with two counts of felony assault. After a jury trial, Defendant was convicted of the lesser-included offense of simple assault and of a serious bodily injury felony assault. Defendant appealed, arguing that the trial justice erred by denying his motion for judgment of acquittal and his motion for a new trial. The Supreme Court affirmed the judgment of conviction, holding (1) there was sufficient evidence to support a conviction of felony assault, and therefore, the trial court did not err in denying Defendant's motion for a new trial; and (2) any analysis of the denial of Defendant's motion for judgment of acquittal was unnecessary. View "State v. Gaffney" on Justia Law

After a jury trial, Defendant was convicted of seven counts of simple assault. At the time of the alleged incidents, Defendant was a captain at the Rhode Island Adult Correctional Institutions (ACI). The charges leveled against Defendant related to his treatment of four ACI inmates. The Supreme Court affirmed the judgment of conviction, holding that the trial justice did not commit reversible error when he (1) denied Defendant's motion to sever his trial from that of his co-defendant; (2) granted the prosecution's motion to preclude the testimony of an inmate; (3) denied Defendant's motion for a new trial; (4) instructed the jury; and (5) allowed the prosecution to introduce certain photographs into evidence that were not disclosed during discovery, as the nondisclosure was inadvertent and did not prejudice Defendant. View "State v. Botas" on Justia Law

Plaintiff was a business agent for a labor organization that represented former employees of the public library. On June 30, the library terminated the employment of thirty-eight union employees. Plaintiff filed a complaint with the Department of Labor and Training (DLT)'s Division of Labor Standards, alleging that the library had failed to pay the employees vacation pay that the employees had accrued at the time of their termination. A hearing officer concluded that the employee's vacation time accrued on July 1 of each fiscal year, and because the employees were not employed on that date, they were not entitled to vacation pay. Plaintiff appealed, The superior court dismissed the complaint for lacking of jurisdiction, ruling that Plaintiff's complaint was untimely filed. The Supreme Court quashed the decision of the superior court and remanded, holding (1) Rule 6 of the Superior Court Rules of Civil Procedure applies to the superior court's review of administrative decisions; and (2) under Rule 6, Plaintiff's complaint would have been timely filed. Remanded. View "McAninch v. State Dep't of Labor and Training " on Justia Law