Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of two counts of first-degree child molestation sexual assault. Defendant appealed, contending, among other things, that the trial justice erred when it denied his motion to suppress statements made to police during a post-arrest interrogation. The Supreme Court (1) affirmed the trial justice’s denial of Defendant’s motion for a new trial and discerned no error arising from the justice’s evidentiary rulings; but (2) remanded the case to the superior court with directions to make additional findings of fact and credibility determinations concerning the voluntariness of Defendant’s confessions, as the trial justice failed to make the findings of fact and credibility determinations essential to support his ultimate finding of voluntariness. View "State v. Bojang" on Justia Law

In 1994, Defendant was charged with felony assault with a dangerous weapon (Count One) and willful or malicious injury to property (Count Two). Count One was dismissed in consideration of Defendant pleading nolo contendere to Count Two. In 2004, Defendant filed a motion to seal with respect to both counts. A justice of the superior court denied the motion. Defendant appealed the hearing justice’s denial of her motion with respect to Count One. The Supreme Court affirmed, holding that the hearing justice did not err when she denied Defendant’s motion to seal Count One pursuant to R.I. Gen. Laws 12-1-12.1(a) because Defendant had not been exonerated of all counts in the criminal case.View "State v. Diamante" on Justia Law

At issue in this case was the Casino Acts, two pieces of legislation providing for the establishment of state-authorized table games at gambling facilities at which Plaintiff, the Narragansett Indian Tribe, received a percentage of income from authorized video lottery terminal (VLT) machines. Plaintiff filed a complaint seeking a declaration that that the Casino Acts were unconstitutional. The superior court concluded that Plaintiff had standing but that Plaintiff failed to meet its burden of proving that the Casino Acts violated the Constitution. Plaintiff appealed, and the State cross-appealed as to the issue of standing. The Supreme Court declined to consolidate the two appeals, and therefore, only the State’s appeal on the issue of standing was before the Court. The Court then affirmed the judgment of the superior court finding that the Tribe was entitled to bring its claims challenging the Casino Act, holding that the reasonable likelihood that the Tribe would suffer a reduction in income from the removal of VLT machines due to the establishment of the table games was sufficient to support a finding that the Tribe had suffered an injury in fact. View "Narragansett Indian Tribe v. State" on Justia Law

Plaintiff executed a promissory note secured by a mortgage on his property. After Plaintiff defaulted on the loan, foreclosure proceedings commenced. Plaintiff subsequently filed a Chapter 7 bankruptcy petition. Then then-holder of the mortgage sought relief from the automatic stay imposed by bankruptcy law. Relief from the stay was given in two bankruptcy cases filed by Plaintiff, the second of which was initiated after a foreclosure sale had been completed. Plaintiff then filed an action seeking a declaration that the foreclosure deed was void and that he owned the property in fee simple absolute. The superior court granted summary judgment against Plaintiff based on the doctrine of res judicata. The Supreme Court affirmed, holding that Plaintiff was precluded from raising issues regarding the foreclosure again in the superior court after the propriety of the foreclosure was examined by the bankruptcy court and the foreclosure sale was declared valid.View "Reynolds v. First NLC Fin. Servs., LLC" on Justia Law

After a jury trial, Defendant was convicted of one count of first-degree child molestation and three counts of second-degree child molestation. On appeal, Defendant argued that the trial justice abused her discretion in refusing to exclude all evidence of uncharged acts of molestation and that the trial justice erred in denying Defendant’s motion for judgment of acquittal and Defendant's motion for a new trial. The Supreme Court affirmed, holding (1) Defendant’s first argument was not preserved for appeal; and (2) the trial justice did not err in denying Defendant’s motions for judgment of acquittal and a new trial. View "State v. Buchanan" on Justia Law

After a jury trial, Defendant was convicted of second-degree child molestation sexual assault. Defendant appealed, arguing that the trial justice erred when she allowed the State to elicit testimony from the complaining witness, which Defendant alleged violated Sup. Ct. R. Crim. P. 16 because the testimony was contrary to the State’s supplemental discovery responses. The Supreme Court affirmed the judgment of the superior court because the content of and the inconsistency among the complaining witness’s statements was disclosed to Defendant and was a proper subject for cross-examination. View "State v. Santiago" on Justia Law

Defendant and the complaining witness (Complainant) lived together while Defendant maintained his own apartment. Due to certain incidents between Defendant and Complainant, Defendant was convicted after a jury trial of one count of simple domestic assault. Defendant appealed, arguing that the trial justice erred in denying his motion for acquittal and in denying his motion for a new trial because the evidence presented at trial did not establish that Defendant and Complainant were in a domestic relationship, as required under R.I. Gen. Laws 12-29-2. The Supreme Court affirmed the judgment of conviction, holding that the trial justice properly found Defendant and Complainant were in a domestic relationship.View "State v. Fleck" on Justia Law

After a jury trial, Defendant was convicted of four counts of first-degree sexual assault and one count of felony assault and battery for his brutal attack of a sixteen-year-old girl. Two years after the attack, law enforcement performed a buccal swab on Defendant, which matched the profile developed from a sample taken from the victim’s underwear. As a result, Defendant was indicted on seven felony counts. The Supreme Court affirmed the judgment, holding (1) the trial justice did not err in denying Defendant’s motion for judgment of acquittal based on the sufficiency of the evidence and Defendant’s motion for a new trial based on alleged errors occurring at trial; and (2) the trial justice did not err in denying Defendant’s motion to exclude the testimony of a forensic evidence analyst who testified at trial. View "State v. Nickerson" on Justia Law

Petitioner applied to the Town of Scituate building official for a building permit to build a single-family home on an unimproved lot. The building official denied the permit, citing numerous deficiencies with Petitioner's plans, including a lack of street frontage. Petitioner appealed the denial and, alternatively, applied for a dimensional variance. The town zoning board denied the appeal and the request for a dimensional variance. The superior court affirmed. The Supreme Court vacated the judgment of the superior court, concluding that the zoning board abused its discretion in determining that a frontage requirement was required for Petitioner's property. Remanded.View "Iadevaia v. Town of Scituate Zoning Bd. of Review" on Justia Law

In 2006, Ingram executed a promissory note in favor of Loancity in the amount of $212,500 to finance the purchase of property in Providence and executed a mortgage on the property. The documents identified Mortgage Electronic Registration Systems (MERS) as “a separate corporation that is acting solely as nominee for Lender and Lender’s successors and assigns.” After a series of assignments in 2009, Deutsche Bank held both the note and the mortgage to the property. Ingram failed to make the required payments. OneWest, under power of attorney for Deutsche Bank, mailed notice that a foreclosure sale on the property was scheduled for March 25, 2010. The foreclosure sale was advertised in the Providence Journal. At the scheduled sale, Deutsche Bank purchased the property for $95,066.40. Ingram sought declaratory relief and to quiet title to the property. The superior court dismissed. The Rhode Island Supreme Court affirmed, rejecting various allegations of improper procedure. View "Ingram v. Mortg. Elec. Registration Sys., Inc" on Justia Law