Justia Rhode Island Supreme Court Opinion Summaries

The case involves Marklyn Brown, who was arrested and indicted for a shooting that resulted in the death of Ms. Berta Pereira-Roldan. During his seven-hour interrogation at the Providence Police Department, Brown consistently maintained his innocence and expressed his desire to speak with his mother. After three hours of questioning, the police allowed Brown to speak with his mother. The conversation between Brown and his mother was recorded and listened to by the police without their knowledge.The Superior Court heard Brown's motions to suppress the statements he made during the interrogation and the recorded conversation with his mother. Brown argued that his Fifth Amendment right against self-incrimination, his Sixth Amendment right to counsel, and his right under article 1, section 13 of the Rhode Island Constitution against self-incrimination were violated. He also argued that the surreptitious recording violated the Fourth Amendment to the United States Constitution, the Rhode Island Constitution, and constituted an unauthorized wiretap pursuant to G.L. 1956 § 11-35-21. The trial justice suppressed both the interrogation and Brown's entire conversation with his mother, determining that Brown had a reasonable expectation of privacy when he spoke to his mother in the interview room.The Supreme Court of Rhode Island affirmed the order of the Superior Court. The court concluded that Brown had a reasonable expectation of privacy when he spoke with his mother in the interview room, and that the police violated Brown's Fourth Amendment rights as well as his rights pursuant to article 1, section 6 of the Rhode Island Constitution when they recorded his conversation with his mother. The court rejected the state's arguments that Brown did not possess a reasonable expectation of privacy because he did not ask for a private, unrecorded conversation, and that he lacked a reasonable expectation of privacy in a police interrogation room. View "State v. Brown" on Justia Law

Danielle LeFebvre was convicted of first-degree child abuse after her seven-week-old son suffered life-threatening injuries. LeFebvre claimed that her son's injuries were accidental, resulting from a fall from her bed. However, medical examinations revealed complex skull fractures, brain contusions, and rib fractures consistent with abuse. LeFebvre was sentenced to twenty years in prison, with eighteen years to serve and the balance suspended, with probation. She appealed her conviction, but it was affirmed.LeFebvre then filed an application for postconviction relief, arguing that she was deprived of effective assistance of counsel. She claimed her trial counsel failed to consult and present a medical expert at trial and disclosed harmful information to the prosecution. The Superior Court denied her application, finding that her counsel's decision to disclose her medical records was a tactical one and that the absence of expert testimony did not deprive LeFebvre of effective assistance of counsel.LeFebvre appealed to the Supreme Court of Rhode Island, which affirmed the judgment of the Superior Court. The court found that while the disclosure of LeFebvre's medical records was objectively unreasonable, it did not deprive her of a fair trial given the overwhelming evidence of her guilt. The court also found that the failure to consult and present an expert at trial did not satisfy the criteria for ineffective assistance of counsel. View "LeFebvre v. State" on Justia Law

The case revolves around a major land development project proposed for multiple parcels of real estate in North Kingstown, Rhode Island. The project was approved by the North Kingstown Planning Commission in 2012. The North Kingstown Town Council amended the zoning ordinance to create a Compact Village District (CVD) zone, which included the developers' property. In 2017, the town council again amended the zoning ordinance for the town’s CVD zone, limiting commercial building coverage and providing a ratio of buildings on the property. The developers challenged the ordinance in federal court, alleging that their project had vested prior to the 2017 ordinance’s limitations. After mediation and settlement discussions, a proposed consent judgment was prepared. The town council approved the consent judgment and the planning commission approved the developers’ preliminary plan for the project.The North Kingstown Zoning Board of Review upheld the planning commission's decision, concluding that the consent judgment recognized the developers’ vested rights and that the project was not bound by the subsequent 2017 zoning amendments. Rickey Thompson, a property owner within 200 feet of the project, filed an action in the Superior Court seeking a declaratory judgment that the town council was not authorized to enter into the consent judgment and that the planning commission should not have relied upon the terms of the consent judgment to review the developers’ application for preliminary plan approval.The Superior Court granted the defendants' motion for summary judgment, finding that Thompson had made an improper collateral attack on the consent judgment, as a nonparty, and that the town had the authority to enter into the agreement. Thompson appealed this decision.The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. The court found that Thompson, as a nonparty to the consent judgment, lacked the requisite standing to challenge the agreement and was thus barred from making a collateral attack on what is a valid, final judgment in federal court. The court also found that the town had the authority to enter into the agreement and the consent judgment did not illegally constrain the planning commission’s authority. The court rejected Thompson’s argument that the consent judgment illegally amended the town’s zoning ordinance. The court also found that Thompson's argument that the town and the developers engaged in contract zoning was not raised in Superior Court and was thus waived. View "Thompson v. Town of North Kingstown Zoning Board of Appeals" on Justia Law

The City of Pawtucket petitioned the Supreme Court of Rhode Island to review a judgment in favor of the Rhode Island Department of Revenue (DOR) and other defendants. The case revolved around two properties owned by The Memorial Hospital, which were deemed ineligible for state aid under the Payment in Lieu of Taxes (PILOT) Act for fiscal years 2021 and 2022. The City argued that the hearing justice erred in upholding the DOR’s interpretation of the PILOT Act, which stated that the properties were not eligible for PILOT funds.Previously, the Superior Court had ruled in favor of the defendants, stating that the DOR's interpretation of the PILOT Act was not arbitrary or capricious, unsupported in the record, or an abuse of discretion. The court concluded that the properties were not owned by a licensed hospital and were therefore ineligible for consideration under the PILOT statute. The City appealed this decision, arguing that the properties should be eligible for PILOT funds because they were still being used for medical care and treatment, even though they were not owned and licensed by the same entity.The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. The court found that the PILOT Act's definition of a "nonprofit hospital facility" required that the hospital-owner of the property also be the holder of a state-issued license. Since Memorial Hospital's license was deactivated in 2018, the properties were deemed ineligible for PILOT funds. The court concluded that the City's argument conflating tax-exempt status with PILOT fund eligibility was unpersuasive, and that the DOR's decision to deny the disbursement of PILOT funds for the properties was not erroneous. View "City of Pawtucket v. Department of Revenue" on Justia Law

The case involves Fuller Mill Realty, LLC (Fuller Mill) and the Rhode Island Department of Revenue Division of Taxation (the Division). Fuller Mill was part of the Rhode Island Historic Preservation Tax Credits Program, administered by the Division. Fuller Mill entered into an agreement with the Division in 2016 for a project. In 2018, the Division notified Fuller Mill that it had forfeited its rights to any historic tax credits for its project due to inactivity. After administrative proceedings and providing supplemental documentation, Fuller Mill's tax credits were reinstated. However, due to delays caused by the COVID-19 pandemic, the Division rescinded Fuller Mill's tax credits in 2020 for failing to complete the project by the agreed deadline. Fuller Mill requested an administrative hearing to challenge the rescission.The Division denied the request for a hearing, leading Fuller Mill to file an appeal in the District Court. The Division filed a motion to dismiss the appeal, arguing that Fuller Mill had waived its right to an administrative hearing and appeal in a stipulation of settlement and dismissal. The District Court denied the Division's motion to dismiss, leading the Division to file a petition for writ of certiorari, which was granted by the Supreme Court.The Supreme Court of Rhode Island found that the terms of the April 2021 stipulation were clear and unambiguous, stating that Fuller Mill had knowingly and voluntarily waived its right to an administrative hearing and to a District Court appeal. The court concluded that the hearing judge erred in denying the Division's motion to dismiss. The Supreme Court quashed the order of the District Court and remanded the case to the District Court with directions to dismiss the case. View "Fuller Mill Realty, LLC v. Department of Revenue" 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

In September 2019, Eleticia Garcia hired Ponagansett 2 LLC, doing business as Peter Bibby Heating & Air, to perform mechanical work on her property. The parties signed two contracts, one for the installation of gas lines, water heaters, and boilers, and another for the installation of baseboards. However, Garcia failed to make the agreed-upon payments, leading Ponagansett to file a mechanics' lien against her property. When Garcia did not respond to the complaint, the Superior Court entered a default judgment in favor of Ponagansett.The Superior Court denied Garcia's subsequent motions to vacate the entry of default, to file a counterclaim out of time, to quash the mechanics' lien, and to file an oral proof of claim. Ponagansett then filed a motion for entry of default judgment against Garcia and a petition for attorneys' fees. The Superior Court granted Ponagansett's request to enforce the mechanics' lien, awarded Ponagansett $20,000 plus interest, and granted attorneys' fees of $12,310.27.On appeal to the Supreme Court of Rhode Island, Garcia argued that the mechanics' lien was unenforceable because Ponagansett failed to provide notice of a possible mechanics' lien as required by law. She also contended that the decisions of the hearing justice to award Ponagansett the full payment of $20,000 and exclude the admission of a mechanical permit were reversible errors. The Supreme Court affirmed the judgment of the Superior Court, holding that Garcia had waived her enforceability argument by failing to timely respond to Ponagansett's complaint. The court also found no error in the hearing justice's award of damages and exclusion of the mechanical permit. View "Ponagansett 2 LLC v. Eleticia Garcia" on Justia Law

A group of developers, collectively referred to as "The Preserve," entered into an agreement in 2011 to purchase land in Richmond, Rhode Island, with the intention of operating an outdoor shooting range and gun club. The town council and planning board initially supported the project, but a subsequent zoning ordinance amendment prohibited such uses. The Preserve was not notified of these changes. In 2016, a new zoning district was created, once again permitting indoor and outdoor shooting ranges. The Preserve claimed that the two-year delay caused substantial revenue loss. They also alleged that the town imposed arbitrary fees, delayed the approval process, and engaged in other discriminatory practices that increased their costs and hindered their development efforts.The Superior Court dismissed The Preserve's claims for violations of substantive due process, tortious interference with contract and prospective business advantages, civil liability for crimes and offenses, and a violation of the civil Racketeer Influenced and Corrupt Organizations (RICO) statute. The court found that the claims were either barred by the statute of limitations or failed to state a claim upon which relief could be granted.The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. The court held that the claims for civil liability for crimes and offenses and civil RICO were barred by a three-year statute of limitations because they were considered torts. The court also found that the statute of limitations was not tolled for the tortious interference claims, as the harm allegedly present was merely the consequence of separate and distinct acts that had occurred prior to the final approval of the land development for the resort. Therefore, all of The Preserve's claims were time-barred. View "The Preserve at Boulder Hills, LLC v. Kenyon" on Justia Law

The defendant, Victor Tavares, was convicted by a jury on two counts of first-degree sexual assault and one count of conspiracy to commit first-degree sexual assault. The charges stemmed from an incident that occurred at a party in 2012, where Tavares and another man, Franklin Johnson, were accused of sexually assaulting a woman named Mary. The evidence against Tavares included Mary's testimony, a used condom found at the scene, and DNA evidence linking Johnson to the condom. Tavares, who represented himself at trial and on appeal, raised twelve issues for consideration.Before the Supreme Court of Rhode Island, Tavares argued that the trial court erred in several ways, including by not dismissing the indictment based on the rule of consistency, the doctrine of collateral estoppel, and the General Assembly's lack of authority to enact criminal laws. He also claimed that the trial court improperly conducted voir dire and allowed the introduction of Johnson's DNA evidence.The Supreme Court rejected all of Tavares's arguments. It held that the trial court properly conducted voir dire and correctly allowed the introduction of Johnson's DNA evidence. The court also found that the General Assembly had the authority to enact the criminal laws under which Tavares was charged and convicted. Furthermore, the court ruled that the doctrines of collateral estoppel and the rule of consistency did not apply in this case. Therefore, the Supreme Court affirmed Tavares's conviction. View "State v. Tavares" 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