Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the superior court granting Defendants' motion to dismiss all electronic, wire, or oral communications obtained through the use of wiretaps and any subsequently-obtained evidence in these consolidated cases, holding that the trial justice did not err.In granting Defendants' motion to suppress, the trial justice found that an associate justice of the superior court had no authority to issue the wiretap orders. The State appealed this ruling and argued, alternatively, that the trial justice erred in concluding that suppression of the evidence derived from the wiretap orders was warranted. The Supreme Court affirmed, holding that the trial court correctly concluded that the associate justice was not vested with the statutory authority to administer and sign the wiretap orders and, therefore, that those orders were in violation of R.I. Gen. Laws 12-5.1, the Interception of Wire and Oral Communications Act. View "State v. McGuire" on Justia Law

The Supreme Court affirmed the judgment of the superior court dismissing Plaintiffs' claims based on lack of standing, holding that there was no error.In 2019, the General Assembly enacted the Reproductive Privacy Act, R.I. Gen. Laws chapter 4.13 of title 23 (RPA), effectively granting a right to abortion in line with Roe v. Wade. 410 U.S. 113 (1973). Plaintiffs initiated this action seeking to halt the passage of House Bill 5125, Substitute B, which later became the RPA. The trial justice denied relief. Plaintiffs then filed a complaint challenging the General Assembly's authority to enact the RPA. The trial court granted Defendants' motion to dismiss for failure to state a claim. The Supreme Court affirmed, holding that Plaintiffs lacked standing to bring their claims. View "Benson v. McKee" on Justia Law

The Supreme Court vacated the decision and order of the superior court declaring Defendant to be in violation of his probation, holding that because Defendant was compliant with court-ordered restitution payments and ran out of time, the remedy could not include incarceration absent a finding of willful violation.Defendant pled nolo contendere to the charge of unlawful appropriation and was ordered to pay restitution. Defendant dutifully paid the amounts set forth in a periodic payment plan but, in anticipation of Defendant's failure to pay restitution in full prior to the expiration of his sentence, the state alleged that Defendant was in violation of his probation. An order subsequently entered declaring Defendant a probation violator. The Supreme Court vacated the decision below, holding that there were other remedies the state could pursue other than incarceration. View "State v. Regan" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree murder, first-degree robbery, and other crimes, holding that Defendant was not entitled to relief on her allegations of error.On appeal, Defendant argued that the trial justice erred in denying her motion to suppress the evidence found at her apartment, denying her motion to suppress the evidence found in her vehicle, and violating her right to confront a witness. The Supreme Court affirmed, holding (1) there was no error in the trial justice's denial of Defendant's motion to suppress the evidence obtained in the apartment based on insufficient probable cause; (2) the trial justice did not clearly err in denying Defendant's request for a Franks hearing; (3) the warrantless seizure of Defendant's vehicle did not violate her rights under either the State or Federal Constitution; and (4) Defendant's Confrontation Clause argument was waived. View "State v. Hudgen" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of possession of child pornography, holding that the State's interesting protecting children from the sexual exploitation portrayed in the images at issue overwhelmingly outweighed Defendant's "expressive interests" in possessing them.Defendant's conviction arise from his possession of computer hard drives or digital storage media containing seventeen computer files of images. The trial justice concluded that six of the images depicted minors engaging in sexually explicit conduct and, based on the six images, convicted Defendant to one count of possession of child pornography. The Supreme Court affirmed, holding that the images depicted unprotected child pornography within the meaning of R.I. Gen. Laws 11-9-1.3. View "State v. Hansen" on Justia Law

The Supreme Court affirmed the order of the family court dismissing Petitioner's verified miscellaneous petition for declaratory judgment, holding that there was no error.This action stemmed from the Department of Children, Youth, and Families' (DCYF) investigation into the maltreatment of Petitioner's biological grandchild, ML. DCYF placed ML with a nonrelative foster family and then terminated Petitioner's son's parental rights to ML. The foster family subsequently adopted ML. Petitioner brought this action seeking a declaration that DCYF violated its statutory obligations by not considering him as a fit and willing relative for ML's placement. The trial justice dismissed the petition after finding that Petitioner lacked standing. The Supreme Court affirmed, holding that Petitioner did not have standing to seek adjudication of his rights to ML when he filed his petition. View "Lacera v. Department of Children, Youth & Families" on Justia Law

The Supreme Court affirmed the final judgment of the superior court in favor of Defendants due to Plaintiff's having failed to comply with her discovery obligations, which had earlier been the subject of a conditional order of dismissal, holding that there was no error.Plaintiff brought this complaint alleging that Defendants had discriminated against her in retaliation for her whistleblowing activities and that she was entitled to relief under the Rhode Island Whistleblowers' Protection Act. Ultimately, the hearing justice granted Defendants' motion for final judgment on the grounds that Plaintiff had, over a five-year period, repeatedly failed to comply with her discovery obligations. The Supreme Court affirmed, holding that the hearing justice acted within her discretion in ordering the entry of final judgment. View "Boss v. Chamberland" on Justia Law

In this commercial dispute, the Supreme Court affirmed the final judgment of the superior court in favor of Defendants based on Plaintiffs' failure to comply with orders to provide discovery, holding that there was no error.The parties in this case executed a contract providing that Defendants would sell finished fiberglass products manufactured by Plaintiffs. Plaintiffs later filed a complaint alleging that Defendants had failed to pay upon delivery of goods and that Defendants conspired to deprive Plaintiffs of profits and sales commission. The trial justice eventually granted Defendants' motion for entry of final judgment, referencing Plaintiffs' failure timely to respond to discovery requests and their failure to comply with superior court orders. The Supreme Court affirmed, holding that the trial justice did not abuse his discretion when he dismissed Plaintiffs' complaint and entered judgment in favor of Defendants. View "EdgengG (Private), Ltd. v. Fiberglass Fabricators, Inc." on Justia Law

In this action for declaratory judgment the Supreme Court reversed the judgment of the superior court denying Family Dollar Stores of Rhode Island, Inc.'s motion for summary judgment and granting summary judgment for Justin Araujo, the complainant in a proceeding before the Rhode Island Commission for Human Rights, holding that the hearing justice erred.Araujo filed a complaint with the Commission alleging that Family Dollar, his employer, had discriminated against him on the basis of an illness. The parties entered into a settlement agreement that included a release. At issue was whether the release unambiguously constituted a waiver by Araujo of his right to pursue all claims he could make against Family Dollar. The hearing justice granted summary judgment in favor of Araujo, entering judgment declaring that the release did not cover Araujo's discrimination claims. The Supreme Court reversed, holding that the release unambiguously precluded Araujo from pursuing a discrimination charge with the Commission. View "Family Dollar Stores of Rhode Island, Inc. v. Araujo" on Justia Law

In this insurance dispute, the Supreme Court affirmed the judgment of the superior court in favor of Defendant following the denial of Plaintiff's request for declaratory judgment and the grant of Defendant's motion for summary judgment, holding that there was no error in the proceedings below.Plaintiff filed a complaint seeking a declaratory judgment that Defendant was required to provide him with full insurance coverage and indemnification for his claims in his underlying personal injury lawsuit. The hearing justice granted summary judgment for Defendant as to all of Plaintiff's claims. The Supreme Court affirmed, holding that Plaintiff was not entitled to relief on his claims of error. View "Dulong v. Merrimack Mutual Fire Insurance Co." on Justia Law