Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the superior court denying Defendant's motion to reduce or correct an illegal sentence, holding that, under the circumstances of this case, the trial court did not err in denying the motion despite the fact that the judgment of conviction did not conform to the oral sentence.In his motion, Defendant conceded that the original sentence imposed was not an illegal sentence but that the error arose from the manner in which the sentence was executed. Specifically, under the law in effect at the time, Defendant was eligible to appear before the parole board after ten years' imprisonment, but it wasn't until eighteen years later that he was first deemed eligible to appear before the parole board. The trial justice denied the motion because Defendant's sentence was not illegal. The Supreme Court affirmed, holding that relief was not available to Defendant. View "State v. Mattatall" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree sexual assault, holding that the trial justice did not abuse its discretion in admitting certain text messages because the evidence was properly authenticated under R.I. R. Evid. 901.The text messages at issue were allegedly sent by Defendant to the complainant. Defendant argued on appeal that because the State did not produce either direct evidence or evidence of distinctive characteristics of the text messages, it did not establish that the text messages were written by Defendant and therefore did not properly authenticate the evidence in accordance with Rule 901. The Supreme Court affirmed, holding that the State produced sufficient circumstantial evidence to establish that Defendant authored the text messages, and therefore, the evidence was properly authenticated under Rule 901. View "State v. Mulcahey" on Justia Law

The Supreme Court affirmed the orders of the superior court dismissing Plaintiff's claims against Defendants, USAA Federal Savings Bank and Charles Baird, for lack of personal jurisdiction, holding that the trial justice was correct in finding that the superior court did not have personal jurisdiction over Defendants.This case stemmed from an alleged oral agreement between Plaintiff and Baird. Plaintiff was a resident of Rhode Island, and Baird was a resident of Florida. Plaintiff filed a complaint against both Baird and USAA, a bank incorporated and based in Texas with whom Baird maintained a personal checking account, seeking to recover certain funds plus consequential damages.The superior court dismissed the case against both defendants for lack of personal jurisdiction. The Supreme Court affirmed, holding (1) the superior court was correct in finding that it did not have either general personal jurisdiction or specific jurisdiction over USAA; and (2) the trial justice was correct in finding that the superior court did not have specific personal jurisdiction over Baird. View "Edward F. St. Onge v. USAA Federal Savings Bank" on Justia Law

The Supreme Court affirmed the decree of the family court terminating Mother's parental rights to her child, holding that the family court did not err when it terminated the rights of Mother, the non-Indian mother of an Indian child who was born suffering from severe medical issues.The trial court terminated Mother's rights after applying the Indian Child Welfare Act (ICWA), finding that the Department of Children, Youth, and Families (DCYF) had met the burden under the ICWA of engaging in active efforts to reunify the child with Mother, and concluding that the child would face serious emotional and physical harm if Mother was given custody of the child. The Supreme Court affirmed, holding that the trial justice did not err when she found that DCYF engaged in "active efforts" to reunify the child with mother as required by the ICWA in section 1912(d). View "In re Roman A." on Justia Law

The Supreme Court vacated in part a family court final judgment of divorce and otherwise affirmed, holding that without a finding as to Wife's ability to pay for her legal representation during the course of the divorce proceedings, the trial justice's denial of Wife's request for attorneys' fees must be vacated and remanded for findings of fact whether to award attorneys' fees under Neb. Rev. Stat. 15-5-16.Specifically, the Court held that the trial justice (1) did not abuse his discretion in denying Wife's request to relocate with the children to Ohio; (2) did not err in awarding temporary use of the home to Wife for thirty months, after which time the home would be sold; (3) did not err in his award of child support; (4) erred in awarding attorneys' fees and costs; (5) did not err in the equitable distribution of the marital property; (6) did not err in setting the visitation schedule; and (7) did not abuse his discretion in determining the amount of sanctions imposed on Husband. View "Saltzman v. Saltzman" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of assault with a dangerous weapon and resisting arrest, holding that the trial justice did not err by denying Defendant's motion for a new trial.On appeal, Defendant argued that the trial justice overlooked and misconceived material evidence concerning the charges of assault with a dangerous weapon and resisting arrest and therefore erred by denying his motion for a new trial. The Supreme Court affirmed, holding that where the trial justice complied with the directives contained in Rule 33 of the Superior Court Rules of Criminal Procedure and articulated adequate grounds for denying Defendant's motion for a new trial, the justice did not err in denying the motion for a new trial. View "State v. Neugent" on Justia Law

In this case stemming from an incident that allegedly took place while Plaintiff was held in pretrial detention at the Adult Correctional Institutions (ACI) the Supreme Court affirmed the judgment of the superior court in favor of Defendants following entry of an order that denied Plaintiff's motion to file a second amended complaint, holding that Plaintiff was not entitled to relief on his allegations of error.In his complaint, Plaintiff, who was serving consecutive sentences of life imprisonment, alleged that he was attacked by a fellow inmate and that the attack was made possible by a correctional officer. Plaintiff sued ACI, the state, and various John Does, alleging negligence for failing properly to protect him. The trial justice granted Defendants' motion to dismiss based on Rhode Island's civil death statute, R.I. Gen. Laws 13-6-1. Thereafter, the trial justice denied Plaintiff's motion to file a second amended complaint. The Supreme Court affirmed, holding (1) the trial justice properly denied Plaintiff's motion to amend; and (2) Plaintiff's arguments that the civil death statute is unconstitutional on various grounds were barred by the "raise-or-waive" rule and procedural law. View "Gallop v. Adult Correctional Institutions" on Justia Law

The Supreme Court affirmed the order of the superior court denying Defendant's motion to dismiss one count of first-degree sexual assault on the grounds of double jeopardy and prosecutorial misconduct, holding that Defendant was not entitled to relief on his claims.Defendant was found guilty of assault and battery and acquitted as to several offenses, but as to the charge for first-degree sexual assault based upon anal penetration, the jury deadlocked and did not reach a verdict. When it became evident that the State would retry Defendant on the deadlocked count, Defendant filed several pretrial motions. Defendant filed a motion to dismiss the sole remaining count, arguing that double jeopardy barred a retrial of acquitted conduct that arose from the same set of facts previously decided by the jury and that the prosecutor engaged in misconduct. Defendant further sought to exclude any reference to acquitted conduct from the first trial. The trial justice denied Defendant's motions. The Supreme Court affirmed, holding (1) Defendant's first argument conflated a double jeopardy contention with one that was evidentiary, and whether Defendant's acquitted conduct was admissible under R.I. R. Evid. 404(b) at his retrial was an issue not properly before the court; and (2) Defendant's prosecutorial misconduct argument was not preserved for appeal. View "State v. Forlasto" on Justia Law

The Supreme Court affirmed the superior court judgment adjudicating Defendant a probation violator and a superior court order denying Defendant's motion to terminate imprisonment, holding that the hearing justices did not act arbitrarily or capriciously or err in denying Defendant's motions.Defendant pled guilty to first-degree sexual assault and assault with a dangerous weapon. Subsequently, Defendant pled nolo contendere to charges of failing to register as a sex offender. Later, a hearing justice adjudicated Defendant a probation violator by failing to keep the peace and be of good behavior. While his first appeal was pending, Defendant filed a pro se motion to terminate his sentence of imprisonment, asserting that the requirements of R.I. Gen. Laws 12-19-18(b)(5) were satisfied under the facts of his case. The hearing justice denied Defendant's motion. The Supreme Court affirmed, holding (1) the hearing justice did not act arbitrarily or capriciously in finding that Defendant had violated the terms of his probation; and (2) the second hearing justice did not err in denying Defendant's motion to terminate his imprisonment because there was ample evidence to support the conclusion that section 12-19-18(b)(5) was inapplicable to the instant case. View "State v. Murray" on Justia Law

The Supreme Court vacated the judgment of the superior court that granted a preliminary injunction in favor of Plaintiffs restraining the City of Woonsocket from changing the terms of Plaintiffs' retiree health insurance, holding that the City had the statutory authority to make changes to Plaintiffs' health care benefits.Plaintiffs, several retried Woonsocket police officers, brought this action against the City and the Woonsocket Budget Commission (the WBC). The superior court granted a preliminary injunction for Plaintiffs and reinstated Plaintiffs' previous postretirement health care benefits. The Supreme Court vacated the judgment, holding that the trial justice (1) did not err when he found that Plaintiffs had a vested contractual right to free lifetime health care benefits; (2) erred when he found that the WBC lacked statutory authority when it adopted the Retiree Resolutions that required Plaintiffs to contribute to their health care expenses; and (3) erred in finding that the WBC violated the Contract Clause of the Rhode Island Constitution when it required Plaintiffs to pay for their health insurance under a new uniform health care plan applicable to all retirees and employees. The Court remanded the case to the trial justice for additional findings. View "Hebert v. City of Woonsocket" on Justia Law