Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of carrying a pistol without a license and possession of a firearm by a person previously convicted of a crime of violence. The Supreme Court affirmed the judgment of conviction, holding (1) the trial justice did not err in denying Defendant’s motion for a judgment of acquittal because the the State produced sufficient evidence at trial from which a jury could infer beyond a reasonable doubt that Defendant possessed the handgun; and (2) the trial justice did not violate Defendant’s right to effective assistance of counsel by restricting defense counsel’s closing argument. View "State v. Ferrer" on Justia Law

Decedent established a Trust that required, upon Decedent’s death, the trustee to distribute a parcel of land to the trustee and to distribute the remainder of the land to Decedent’s children. The Trust filed a complaint for eviction for unlawfully holding over after the termination of tenancy against Defendants, Decedent’s children. The district court entered judgment in favor of the Trust. Defendants appealed, arguing that the Trust was not a landlord and Defendants were not tenants, but rather, tenants in common with the trustee. Therefore, Defendants argued, an action for eviction could not lie. The superior court granted Defendants’ motion to dismiss, concluding that the court lacked subject matter jurisdiction and that the Trust lacked standing. The Supreme Court vacated the judgment of the superior court, holding that the superior court did have jurisdiction over trespass and ejectment matters, and therefore, the motion justice erred in dismissing the case for lack of subject matter jurisdiction. Remanded for an evidentiary hearing with respect to the issue of standing. View "Joseph P. Notarianni Revocable Trust v. Notarianni" on Justia Law

After a jury trial, Defendant was convicted of possession with intent to deliver cocaine. Defendant appealed, arguing that the trial court erred by not excluding evidence that he was carrying cash at the time of his arrest and in denying him any remedy for the State’s late disclosure of that evidence. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not abuse its discretion in admitting the evidence, as the fact that Defendant had some amount of cash on his person at the time of the arrest was not unfairly prejudicial evidence. View "State v. Marte" on Justia Law

Power Survey Company sought a writ of certiorari before the Supreme Court contending that the Public Utilities Commission improperly interpreted and applied the Contact Voltage Statute when it approved the portion of the Narragansett Electric Company’s (NEC) contact voltage program providing for the issuance of a request for proposal for the purpose of choosing a vendor to provide the technology for the NEC’s contact voltage testing. The Supreme Court issued the writ. Respondents, the NEC and the Division of Public Utilities and Carriers, moved to quash the writ on the grounds that it was not timely filed. The Supreme Court granted Respondents’ motions, holding that, under the facts of this case, Power Survey’s petition was untimely. View "In re Proceedings to Establish a Contact Voltage Detection & Repair Program" on Justia Law

After unsuccessfully seeking reimbursement from the State Commissioner of Elementary and Secondary Education, Plaintiffs, a school district and school department, filed a complaint in the superior court alleging that the Commissioner and State Treasurer were required to reimburse them for the salary, fringe benefits, and travel expenses of the directors and guidance counselors in their vocational-technical programs. The superior court dismissed the complaint, concluding that Plaintiffs had an adequate remedy at law and that the Commissioner’s decision to deny Plaintiffs reimbursement was discretionary in nature, rather than ministerial. Plaintiffs subsequently sought a writ of mandamus. The Supreme Court affirmed the judgment of the superior court, holding that Plaintiffs did not have a clear legal right to be reimbursed for certain costs associated with the operation of their career and technical centers. View "Chariho Reg’l Sch. Dist. v. Gist" on Justia Law

After a jury trial, Defendant was convicted of one count of voluntary manslaughter. Defendant appealed the trial justice’s denial of her motion for a new trial, arguing that the State failed to meet its burden of proving beyond a reasonable doubt that she did not act in self-defense when she killed the victim. The Supreme Court affirmed the superior court’s judgment of conviction, holding that the trial justice did not overlook or misconceive material and relevant evidence and was not otherwise clearly wrong in her denial of Defendant’s motion for a new trial. View "State v. Garrett" on Justia Law

Defendant was charged with two counts of first-degree robbery in connection with two armed robberies. Defendant filed several motions to suppress evidence obtained by police detectives following his arrest. A hearing justice granted Defendant’s motion to suppress certain evidence under the exclusionary rule to the Fourth Amendment to the United States Constitution because the evidence was gathered after an “illegal” extra-jurisdictional arrest. The Supreme Court vacated the order of the superior court, holding (1) the detectives’ actions in arresting Defendant outside their jurisdiction were in excess of their authority; but (2) the exclusionary rule of the Fourth Amendment did not mandate the suppression of the evidence obtained in this case. View "State v. Morris" on Justia Law

After a jury-waived trial, Defendant was convicted of one count of domestic felony assault and one count of domestic simple assault. On appeal, Defendant argued, among other things, that the trial justice erred in denying his motion to dismiss the criminal information, which contained the two counts on which Defendant was convicted. The Supreme Court affirmed, holding (1) the criminal information was sufficient to establish probable cause for the two counts for which Defendant was convicted; and (2) the trial justice did not commit any evidentiary errors during the course of the trial. View "State v. Ceppi" on Justia Law

Son was born to Mother, who was incarcerated at the time of the birth. Father was also incarcerated at that time. The Department of Children, Youth, and Families (DCYF) filed a petition to terminate the parental rights of both parents, alleging that Mother and Father had chronic substance-abuse problems and that Son had been placed in the legal custody of DCYF for at least twelve months with no substantial probability that Son would be able to return to the parents’ custody within a reasonable period of time. After a hearing, the hearing justice terminated Father’s parental rights. The Supreme Court affirmed the decree terminating Father’s parental rights, holding (1) the trial justice did not abuse his discretion in finding that Father was unfit and that it was improbable that Son would be able to return to Father’s care within a reasonable period of time; and (2) the trial justice did not clearly err in finding that DCYF had met its burden to make reasonable efforts under R.I. Gen. Laws 15-7-7(b)(1). View "In re Lyric P." on Justia Law

Plaintiffs purchased a home. To finance the transaction, Plaintiffs executed a note payable to Accredited Home Lenders. The note was secured by a mortgage on the property naming Mortgage Electronic Registration Systems, Inc. (MERS) as the mortgagee. MERS assigned the mortgage to Deutsche Bank National Trust Company. Because Plaintiffs stopped making their payments as set forth in the note Deutsche Bank foreclosed on the property. Accredited REO Properties purchased the property. Plaintiffs subsequently filed a complaint seeking declaratory judgment and injunctive relief seeking orders declaring that they were owners of the property as a matter of law and that the foreclosure sale, conveyance, and assignment were void. Defendants - MERS, Deutsche Bank, Accredited REO Properties, Accredited Home Lenders, and others - filed a motion for summary judgment, which the district court granted. The Supreme Court affirmed, holding that a legal and valid foreclosure occurred in this case. View "Moura v. Mortgage Elec. Registration Sys., Inc." on Justia Law