Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s conviction of reckless driving, holding that the trial justice did not commit clear error or overlook or misconceive material or relevant evidence in denying Defendant’s motion for a new trial.In his motion for a new trial, Defendant argued that the evidence presented at trial was insufficient to convict him of reckless driving and that the jury did not note the specific location where Defendant’s alleged reckless driving took place. The trial justice denied the motion. The Supreme Court affirmed, holding that the trial justice did not clearly err or misconceive material evidence and did not err in denying Defendant’s motion for a new trial. View "State v. Silva" on Justia Law

The Supreme Court affirmed the judgment of the superior court dismissing Plaintiff’s probate court appeals for his failure to comply with several court orders, holding that the superior court justice properly exercised his discretion in dismissing Plaintiff’s appeals.Ostensibly acting as successor executor for the wills of two former clients, Appellant challenged probate court orders relating to guardianship decrees. The superior court dismissed Appellant’s five probate court appeals for Appellant’s failure to comply with the court’s orders. The Supreme Court affirmed, holding (1) the superior court justice did not abuse his discretion; and (2) because Appellant’s representations to the probate courts, the superior court, and the Supreme Court were not as forthcoming as the rules of procedure require, the case is remanded to allow Defendants an opportunity to file a motion for sanctions if they so choose. View "Malinou v. Neri" on Justia Law

The Supreme Court vacated the judgment of the superior court entering judgment in favor of Defendant on Plaintiff’s claim that Defendant terminated her employment in violation of the Fair Employment Practices Act (FEPA), holding that Plaintiff complied with the statutory requirements for commencing a FEPA violation action in superior court.Defendant moved to dismiss Plaintiff’s complaint on the basis that, as to the FEPA claim, Plaintiff had not properly and timely requested a right-to-sue letter from the Rhode Island Commission for Human Rights as required by R.I. Gen. Laws 28-5-24.1. The Commission intervened. The hearing justice granted Defendant’s and the Commission’s motions to dismiss, concluding that Plaintiff had not timely requested a right-to-sue letter. The Supreme Court vacated the judgment below, holding that, based on the circumstances of this case, Plaintiff complied with the requirements of section 28-5-24.1 for bringing this FEPA action. View "Mokwenyei v. Rhode Island Hospital" on Justia Law

The Supreme Court affirmed the judgment of the superior court finding Defendant guilty of one count of second-degree murder and one count of discharging a firearm while committing a crime of violence, holding that the trial justice did not err in denying Defendant’s motion to suppress or in failing to exclude certain evidence.Specifically, the Court held (1) law enforcement’s failure to comply with Miranda does not require the suppression of the physical evidence acquired as a result of a suspect’s unwarned, but voluntary, statements; (2) Defendant’s statements leading detectives to a firearm and ammunition were voluntary, and therefore, the gun and ammunition were admissible; and (3) the trial justice did not err in concluding that the police’s seizure through the impounding of Defendant’s vehicle and the subsequent search of the vehicle were constitutional, and therefore, the evidence obtained therein admissible. View "State v. Beauregard" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Appellant’s application for postconviction relief, holding that Appellant was not entitled to postconviction relief.Appellant was found guilty of murder in the first degree and other offenses and sentenced to life imprisonment. Appellant later filed the instant application for postconviction relief alleging that he was denied effective assistance of trial and appellate counsel. After a hearing, the hearing justice denied the application for postconviction relief. The Supreme Court affirmed, holding that there was no ineffective assistance of either Appellant’s trial or appellate counsel, and therefore, the hearing justice properly denied Appellant’s application for postconviction relief. View "Jimenez v. State" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of second-degree sexual assault for having sexually assaulted a fifteen-year-old neighbor, holding that the trial justice did not commit reversible error.Specifically, the Court held (1) the trial justice did not commit reversible error by sustaining the prosecutor’s objection to defense counsel’s question to the complainant as to whether he had received any professional counseling with respect to the events at issue in this case; (2) Defendant waived his argument that the trial court erred in not striking Defendant’s wife’s response to the prosecutor’s questions about contacting the complainant or his family; and (3) the trial justice did not err in overruling the defense objection to Defendant’s wife’s testimony that she and Defendant lived on the side of an elementary school. View "State v. MacNeil" on Justia Law

The Supreme Court affirmed the decree of the Family Court terminating Father’s parental rights with respect to his daughter, holding that that any errors complained of were harmless beyond a reasonable doubt.Specifically, the Court held that the Family Court justice (1) did not abuse her discretion by qualifying a certain witness as an expert and relying on her testimony; (2) admitting the child’s letter into evidence pursuant to R.I. R. Evid. 803(4); and (3) taking judicial notice of Form 188, the Disclosure of Permanency Planning form. View "In re Izabella G." on Justia Law

The Supreme Court quashed the judgment of the superior court denying Appellant’s application for postconviction relief and remanded the case for further factfinding in light of this Court’s opinion in State v. Gibson, 182 A.3d 540 (R.I. 2018), holding that Gibson controlled the legal issue in this case.In 1993, Appellant was convicted of a sexual offense. Appellant’s duty to register was governed by R.I. Gen. Laws 11-37-16, the registration statute in place at the time of that conviction. Pursuant to the holding in Gibson, however, the duration of the duty to register was controlled by the present version of section 11-37.1-4(a). Because the record on review was inadequate to enable this Court to define the correct contours of the duration of Appellant’s duty to register, the Court quashed the judgment of the superior court and remanded for further proceedings in light of Gibson. View "Atryzek v. State" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting Defendants’ motion to dismiss this action pursuant to Rule 41(b)(2) of the Superior Court Rules of Civil Procedure, holding that the motion justice did not abuse his discretion in dismissing the complaint.Plaintiff filed this action in 2010, but service was not completed at that time. In 2015, Plaintiff had copies of the complaint and summonses served upon Defendants. Defendants filed a motion to dismiss based on lack of prosecution and failure to serve process upon Defendants within the time required in Rule 4(1) of the Superior Court Rules of Civil Procedure. The motion justice dismissed the action, with prejudice, under Rule 41(b). The Supreme Court affirmed, holding that, given the five-year delay in serving the complaint and the lack of any explanation for the delay, the motion justice did not abuse his discretion in dismissing the complaint. View "Duffy v. Town of West Warwick" on Justia Law

The Supreme Court affirmed the judgment of the superior court finding Defendant guilty of second-degree child abuse, holding that no prejudicial error occurred in the proceedings below.Specifically, the Court held (1) to the extent that certain testimony may have been improperly admitted, it was harmless; (2) the trial justice clearly articulated a basis for his fining that the injury requirement of the second-degree child abuse statute had been met, and therefore, the court need not reach the question of a lesser-included offense; and (3) the trial justice did not err by denying Defendant’s motion for a new trial. View "State v. Cahill" on Justia Law