Justia Rhode Island Supreme Court Opinion Summaries
State v. Pires
The case involves Napoleao Pires, who was convicted for carrying a firearm without a license and possession of a controlled substance. The conviction was based on evidence obtained when a police officer, responding to a dispatch, stopped and searched Pires. The dispatch reported a man matching Pires' description walking around with a gun. Upon arrival, the officer did not observe any criminal activity or see a gun, but stopped Pires based on the dispatch information. Pires challenged the trial justice’s decision to deny his motion to suppress the evidence, arguing that the seizure violated his constitutional rights under the Fourth Amendment.The Superior Court held a hearing on the motion to suppress and concluded that the gun and cocaine had been lawfully seized. The court found that the officer's thirty years of experience, the dispatch sending him to a high-crime area, Pires' match to the dispatch description, Pires' noncompliance to the officer’s commands, and Pires' pivot to reach for his waistband amounted to the level of reasonable suspicion required to justify the warrantless stop.The Supreme Court of Rhode Island reversed the decision on the motion to suppress and vacated the judgment of conviction. The court held that Pires was seized the moment he complied with the officer’s order to raise his hands. The court found that the state failed to submit adequate evidence to show that reasonable suspicion existed at the inception of Pires' encounter with the officer. The court concluded that Pires' Fourth Amendment rights were violated because the state failed to submit adequate evidence to show that reasonable suspicion existed at the inception of his encounter with the officer. View "State v. Pires" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Glassie v. Doucette
This case involves a dispute over the Estate of Donelson C. Glassie. The plaintiff, Marcia Sallum Glassie, was married to Donelson C. Glassie, and they divorced in 1993. According to their property-settlement agreement, the testator was to execute a will that would treat his obligations under the agreement as a claim against his estate and bequest to the plaintiff an amount equal to said obligations. A dispute arose over what the agreement required of the testator’s will. In 1997, a Family Court justice determined that the plaintiff was entitled to a bequest of a sum equal to the testator’s obligations. The testator died in 2011, and the plaintiff filed a claim for $2,000,000 against the testator’s estate a year later, which the defendant disallowed.The case was previously reviewed by the Superior Court, which awarded the plaintiff $2,000,000, less the proceeds of a life insurance policy that she received upon the testator’s death and attorneys’ fees. However, this judgment was vacated by the Supreme Court on multiple grounds, including that the disputed provision in the will was ambiguous and required factfinding and conclusions of law with respect to the testator’s intent.In the current review by the Supreme Court of Rhode Island, the plaintiff argued that the trial justice made numerous prejudicial evidentiary rulings that prevented her from presenting her case. After reviewing the record and considering the parties’ arguments, the Supreme Court affirmed the judgment of the Superior Court. The court found no error in the trial justice’s decisions to prevent the plaintiff from presenting evidence regarding a trust, to allow the defendant to withdraw certain admissions, to admit evidence of a life insurance policy, and to allow evidence of the defendant’s post-death conduct. The court also found that the plaintiff had not preserved her argument regarding the trial justice’s decision to prevent her from examining the defendant about his counterclaim. View "Glassie v. Doucette" on Justia Law
Posted in:
Family Law, Trusts & Estates
Rhode Island Troopers Association v. State of Rhode Island
This case revolves around the denial of a disability pension application by a former state trooper, James Donnelly-Taylor. The defendants are the State of Rhode Island, Division of the State Police, and the Colonel of the State Police and Governor in their official capacities. The trooper had been involved in an incident where he assaulted an individual he had arrested. Following this incident, he reported experiencing personal and work-related stress and was placed on injured-on-duty status. Later, he was indicted on one count of simple assault. He pleaded nolo contendere to the assault charge and was ordered to perform community service. The trooper remained out of work and was later diagnosed with post-traumatic stress disorder and major depressive disorder. He applied for a disability pension, which was denied by the superintendent of the state police.The superintendent's decision was appealed to the Superior Court, which found the denial to be arbitrary and capricious. The court remanded the case back to the superintendent for further consideration. The superintendent issued a supplemental decision, maintaining the denial of the disability pension. The Superior Court again found the superintendent's decision to be arbitrary and capricious and reversed the denial, instructing the superintendent to grant the trooper's request for a disability pension.The State of Rhode Island appealed the Superior Court's decision to the Supreme Court of Rhode Island. The Supreme Court reversed the Superior Court's decision, finding that the superintendent's denial of the disability pension was neither arbitrary nor capricious. The court held that the superintendent had reasonable grounds to conclude that the trooper's assault of the individual was not in the course of performance of his duties as a state police officer, and therefore his disabling injuries were not suffered in the course of performance of his duties. The case was remanded back to the Superior Court with instructions to enter judgment in favor of the defendants. View "Rhode Island Troopers Association v. State of Rhode Island" on Justia Law
Glassie v. Doucette
This case involves a dispute over the will of the late Donelson C. Glassie. The plaintiff, Marcia Sallum Glassie, is the testator’s former wife. She appealed from a Superior Court judgment in favor of the defendant, Paul Doucette, in his capacity as Executor of the Estate of Donelson C. Glassie. The Superior Court affirmed an order of the Newport Probate Court denying the plaintiff’s petition for leave to file a claim out of time against the estate. The denied claim would have alleged a breach of contract, based on the plaintiff’s contention that a key provision of the testator’s will violated the terms of the couple’s property-settlement agreement.The plaintiff and the testator were married in 1986, had three children, and were divorced in 1993. According to their property-settlement agreement (PSA), the testator was to execute a will that would not only treat his obligations under the PSA as “a claim against any assets in [his] [e]state” but also “specifically bequest to [plaintiff] an amount equal to said obligations.” A dispute soon unfolded over what the PSA required of the testator’s will.In 2017, the Supreme Court of Rhode Island vacated the Superior Court judgment on multiple grounds. Relevant to the present appeal, the court determined “that the disputed provision in the will is ambiguous” because it “does not clearly specify under what circumstances plaintiff is to receive the sum of $2,000,000 or the circumstances under which she is to receive such other amount necessary to satisfy all of [the testator’s] remaining obligations.” Because “a proper resolution of this matter require[d] factfinding and conclusions of law with respect to [the] testator’s intent,” the court remanded the case to the Superior Court.Back in Superior Court, the plaintiff sought to amend her complaint with a claim for breach of contract. The Superior Court denied plaintiff’s motion to amend her complaint, in part because she did not first submit the claim to the probate court, and also because the applicable statute of limitations had expired. The plaintiff thereafter filed a petition in the Newport Probate Court for leave to file a claim out of time and, after the court denied her petition, she appealed that denial to the Superior Court.The Supreme Court of Rhode Island affirmed the judgment of the Superior Court, concluding that the plaintiff’s failure to timely present her claim for breach of contract was not due to excusable neglect and, therefore, her claim must be denied. View "Glassie v. Doucette" on Justia Law
Newport School Committee v. Rhode Island Department of Education
The case involves the Newport School Committee and the Cumberland School Committee (collectively, plaintiffs) and the Rhode Island Department of Education and the Rhode Island Council on Elementary and Secondary Education (collectively, defendants). The dispute arose when the plaintiffs refused to reimburse the Department of Children, Youth, and Families (DCYF) at the "per-pupil special-education" rate for the cost of educating children who were placed in residential treatment programs by DCYF but were not receiving special-education services. The Family Court had placed two children in the temporary custody of DCYF and designated Newport and Cumberland as the residences of the children's custodial parents for the purpose of determining the municipalities' financial responsibility for the children's education.The Commissioner of Elementary and Secondary Education agreed with DCYF's argument that the municipalities were required to pay the per-pupil special-education rate according to the unambiguous language of the relevant statutes. The Commissioner issued two decisions ordering Newport and Cumberland to reimburse DCYF for the cost of educational services provided to the children at the special-education rate. After the Council on Elementary and Secondary Education denied the municipalities' independent appeals of the Commissioner's decisions, the municipalities appealed to the Superior Court. The trial justice consolidated the two cases and issued a written decision, determining that the clear and unambiguous language of the statute required the designated city or town to pay its share of the cost of educational services to DCYF rather than the higher, per-pupil special-education rate.The Supreme Court of Rhode Island reviewed the case and found that there is nothing in the relevant statutes that expressly obligates a municipality to pay the per-pupil special-education rate when the child in question is not actually receiving special-education services. The court concluded that municipalities are not required to reimburse DCYF at the per-pupil special-education rate when there were no special education services rendered and thus, no special education costs incurred. The court directed the parties to file supplemental briefs to resolve the remaining question of what reimbursement, if any, DCYF should receive for the educational cost of non-special-education students placed in residential treatment programs that include the delivery of educational services. View "Newport School Committee v. Rhode Island Department of Education" on Justia Law
Posted in:
Education Law, Government & Administrative Law
Armour v. Bader
This case involves a medical negligence claim brought by John Armour, individually and as personal representative of the Estate of Judith Armour, against David Bader, M.D., Neil Brandon, M.D., and South County Hospital Healthcare System d.b.a. South County Cardiology. The plaintiff alleges that the defendants negligently failed to provide adequate follow-up and treatment to Judith Armour following a stress test, which ultimately led to her death from a heart attack the next day. The stress test results were "markedly abnormal" and indicated potential significant coronary artery disease, but Mrs. Armour was sent home after the staff determined she was medically stable.The case was tried in the Washington County Superior Court. The jury heard testimony from various witnesses, including the nurses, the defendant-doctors, Mrs. Armour’s family, and expert testimony from both sides regarding the applicable standard of care and causation. The jury returned a verdict in favor of the defendants on all counts. The plaintiff filed a motion for a new trial, arguing that the jury’s verdict was against the fair preponderance of the evidence and that the trial justice erred in several respects. The trial justice denied the motion, concluding that the overwhelming weight of the evidence supported the jury’s verdict.On appeal to the Supreme Court of Rhode Island, the plaintiff argued that the trial justice erred in refusing to issue a jury instruction based on a previous court decision, erred in permitting defendants’ standard-of-care expert to utilize the referring doctor’s records, and erred in limiting cross-examination of that expert regarding a particular study. The Supreme Court found that the trial justice's refusal to issue the requested jury instruction was prejudicial and constituted reversible error. The court also found that it was an error to allow the expert to use the referring physician’s records to support his opinions as defendants did not have access to this information when determining if Mrs. Armour was stable. Lastly, the court concluded it was an abuse of discretion to limit cross-examination on a point that went to the heart of the most important standard-of-care issue in the case. The judgment of the Superior Court was vacated and the case was remanded for a new trial. View "Armour v. Bader" on Justia Law
State v. Finnigan
The case involves Nicholas Finnigan, who was convicted of one count of second-degree child molestation following a jury-waived trial in the Superior Court. The incident allegedly occurred in February 2012, when the victim, R.B., was under fourteen years old. Finnigan was sentenced to ten years, with fifty-four months to serve and the remainder suspended, and ten years of probation. Finnigan appealed the conviction, arguing that the trial justice overlooked or misconceived material evidence.The Superior Court heard testimonies from several witnesses, including the victim, R.B., who testified that Finnigan touched her inappropriately while she was sleeping in her bedroom. Other witnesses corroborated aspects of R.B.'s account, including her mother and aunt who testified that they saw Finnigan leaving R.B.'s room on the night of the incident. Finnigan denied the allegations and claimed he never entered R.B.'s bedroom on the night in question. The trial justice found R.B. to be a credible witness and concluded that Finnigan was guilty of second-degree child molestation.The case was brought before the Supreme Court of Rhode Island. Finnigan argued that the trial justice overlooked or misconceived material testimony about the night of the alleged incident and failed to properly weigh the conflicting testimony regarding the actual date of the alleged incident. The Supreme Court, after reviewing the record, concluded that sufficient competent evidence existed to support the trial justice’s general finding of guilt beyond a reasonable doubt on the charge of second-degree child molestation. The court affirmed the judgment of the Superior Court, stating that the trial justice did not misconceive or overlook the inconsistent testimony about the date of the incident. The court also noted that there is no requirement of independent corroboration for sex-offense cases. View "State v. Finnigan" on Justia Law
Posted in:
Criminal Law
State v. Alicea
The defendant, Lydia Alicea, was charged with violating a law between February 18, 2017, and August 1, 2017. On June 19, 2020, she pleaded nolo contendere and was given a two-year deferred sentence and ordered to pay $1,800 in restitution. Alicea entered into a deferred-sentence agreement with the Office of the Attorney General, agreeing to the terms of her sentence, including the payment of restitution. However, she failed to pay the court-ordered restitution in accordance with the agreement. Almost two years later, the state filed a notice of violation and Alicea appeared before a Superior Court magistrate.The magistrate inquired whether Alicea had the ability to pay the outstanding balance before the expiration of her sentence. Alicea represented that she could satisfy the outstanding amount before the deferred-sentence agreement expired, as she had recently become employed. However, she failed to make any payments towards her outstanding balance. The court scheduled a violation hearing based on Alicea’s failure to comply with the restitution obligation of her deferred-sentence agreement. At the hearing, Alicea submitted a hand-written financial statement in support of her argument that she was unable to pay restitution. The court found Alicea in violation of the deferred-sentence agreement and imposed a sentence of three years of probation and ordered her to pay $36.15 in monthly installments toward the outstanding restitution amount.Alicea appealed the magistrate’s decision to a justice of the Superior Court. The trial justice denied the appeal and the restitution payments were set to resume. Alicea then appealed to the Supreme Court of Rhode Island. The Supreme Court vacated the judgment of the Superior Court and remanded for further proceedings, stating that Alicea was entitled to an evidentiary hearing regarding her ability to pay before a sentence could be imposed. View "State v. Alicea" on Justia Law
Posted in:
Criminal Law
Neves v. State of Rhode Island
This case involves four individuals, Joao Neves, Keith Nunes, Pablo Ortega, and Mario Monteiro, who were convicted of various crimes in Rhode Island and were serving multiple sentences, including life sentences. The issue at hand is the interpretation of a Rhode Island statute, G.L. 1956 § 13-8-13(e), which was enacted in 2021 and provides that any person sentenced for any offense committed prior to their twenty-second birthday, other than a person serving life without parole, shall be eligible for parole review after serving no fewer than twenty years' imprisonment.The state argued that the statute applies only to individuals serving a single sentence and does not require the aggregation of multiple sentences for parole eligibility. The respondents, on the other hand, argued that the statute applies to "any offense," and thus requires the aggregation of multiple sentences, including consecutive sentences, for parole eligibility.The trial justice agreed with the respondents and ordered that each respondent be immediately released on parole. The state appealed, arguing that the trial justice's interpretation of the statute violated the separation-of-powers doctrine by modifying judicial sentences.The Supreme Court of Rhode Island held that the statute mandates the aggregation of a qualified offender’s sentences, including consecutive sentences, for parole eligibility. The court also concluded that the statute, as interpreted, does not violate the separation-of-powers doctrine. However, the court found that the trial justice erred in ordering each respondent to be immediately released on parole, as the statute only provides a qualified offender the opportunity to appear before the parole board, not the right to be paroled. The court affirmed in part and vacated in part the judgments of the lower court, and remanded the cases to the parole board for further proceedings. View "Neves v. State of Rhode Island" on Justia Law
Posted in:
Criminal Law, Government & Administrative Law
State v. Mather
Edward Mather, the defendant, was charged with multiple counts of domestic assault, vandalism, and violation of a no-contact order. Following his arraignment, he was ordered to undergo a psychiatric evaluation to determine his competency to stand trial. The evaluation concluded that Mather was incompetent to stand trial and required hospitalization. Subsequently, he was committed to an outpatient facility, LaBelle House Group Home, under the custody of the Department of Behavioral Healthcare, Developmental Disabilities and Hospitals (BHDDH).The Superior Court held a commitment hearing and based on a report from BHDDH, found Mather remained incompetent to stand trial. The court ordered Mather to remain committed to BHDDH's custody but allowed him to be placed in an outpatient facility without endangering himself or others. The court also ordered that if Mather violated the conditions of the order, engaged in threatening or aggressive behavior, or required hospitalization, he should be immediately returned to Eleanor Slater Hospital.Mather filed a petition to discharge from the detention order of commitment in both of his pending criminal matters. He argued that his continued institutionalization at the outpatient facility restricted his liberty and violated due process. The trial justice denied Mather's petitions, reasoning that his commitment to the outpatient facility did not constitute "detention" pursuant to the relevant statute. Mather sought review of the decision, and the Supreme Court of Rhode Island granted the petitions, consolidated the cases for review, and issued the writ.The Supreme Court of Rhode Island quashed the orders of the Superior Court and remanded the matter for further proceedings. The court held that the trial justice committed a reversible error of law when he denied the petitions to discharge from detention orders of commitment. The court concluded that Mather's continued commitment no longer bore a reasonable relationship to the purpose of his commitment under the relevant statute. The court held that where a defendant is found to be incompetent to stand trial and competency is nonrestorable prior to the statutory dismissal period, the defendant is entitled to be discharged from detention under the order of commitment thirty days thereafter. View "State v. Mather" on Justia Law
Posted in:
Civil Rights, Criminal Law