Articles Posted in Rhode Island Supreme Court

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The Supreme Court affirmed Defendant's conviction of two counts of first degree robbery and one count of conspiracy to commit robbery, holding that the admission of an out-of-court statement made by an alleged coconspirator who did not appear at Defendant's trial, was harmless beyond a reasonable doubt. While the sole issue on appeal was whether Defendant's Sixth Amendment confrontation rights were violatedl. The Court held (1) this Court assumes, without deciding, that a Confrontation Clause objection was properly articulated; and (2) because the remaining evidence was sufficiently compelling to support the jury's finding of guilty, the admission of the coconspirator's out-of-court declaration was harmless beyond a reasonable doubt. View "State v. Sanchez" on Justia Law

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The Supreme Court vacated the September 20, 2016 judgment of the superior court entering judgment against Family Dollar Stores of Rhode Island, Inc. and affirmed the November 9, 2016 order of the superior court granting Family Dollar's emergency motion for a thirty-day extension of time within which to file its notice of appeal, holding that the hearing justice erred in dismissing Family Dollar's declaratory judgment action. Family Dollar filed this action against Justin B. Araujo seeking a declaratory judgment that the parties had entered into an enforceable settlement agreement releasing Family Dollar from claims that Araujo asserted against it in his charge before the Rhode Island Commission for Human Rights and also alleging breach of contract. The Commission was added as an additional party to the case. The hearing justice granted Defendants' motions to dismiss on the basis that the proper forum for this action was before the Commission. Family Dollar later filed an emergency motion for a thirty-day time extension, which the hearing justice granted. The Supreme Court affirmed in part and vacated in part, holding (1) the hearing justice did not abuse his discretion in finding excusable neglect in this case; and (2) Family Dollar's declaratory judgment action may proceed in superior court on remand. View "Family Dollar Stores of Rhode Island, Inc. v. Araujo" on Justia Law

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The Supreme Court affirmed Defendant's conviction of four counts of first-degree child molestation sexual assault, holding that Defendant was not entitled to a new trial based on any of his arguments on appeal. Specifically, the Court held (1) the trial justice did not err when he accepted a jury waiver form that Defendant had signed outside the presence of the trial justice; (2) Defendant's colloquy with the trial justice demonstrated that Defendant knowingly, intelligently, and voluntarily waived his right to a jury trial; and (3) the trial justice adequately explained the differences between a jury trial and a bench trial. View "State v. Morais" on Justia Law

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In this complaint brought against Rhode Island College and various college officials alleging that Defendants’ conduct toward Plaintiff during his enrollment in the Master of Social Work program due to his political beliefs violated his constitutional rights the Supreme Court vacated in part and affirmed in part the judgment of the hearing justice granting summary judgment in favor of Defendants and dismissing Plaintiff’s claim for punitive damages, holding that summary judgment must be vacated as to certain counts. Specifically, the hearing justice held that Defendants were entitled to summary judgment on Plaintiff’s claims that Defendant violated his constitutional rights to freedom of expression and equal protection, conspired to violate his civil rights, and violated his procedural due process rights. The hearing justice also found that Plaintiff had not established a prima facie case for punitive damages. The Supreme Court held (1) summary judgment was improper as to Plaintiff’s freedom of speech claims; (2) summary judgment was proper as to Plaintiff’s equal protection and procedural due process claims; (3) Defendants were entitled to judgment as a matter of law on Plaintiff’s conspiracy claim; and (4) the hearing justice properly found that Plaintiff had not met his burden to demonstrate a prima facie case for punitive damages. View "Felkner v. Rhode Island College" on Justia Law

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The Supreme Court vacated the judgment of conviction after a jury found Defendant guilty of first degree sexual assault and murder, holding that Defendant was entitled to a new trial because the trial court violated the Confrontation Clause. In this cold case, Defendant was charged with the crimes for which he was convicted twenty-five years after the victim was murdered. On appeal, Defendant argued, among other things, that the trial justice erred by allowing statements of deceased declarants to be admitted into evidence, in violation of the Confrontation Clause. The Supreme Court agreed and vacated Defendant’s convictions, holding (1) the Confrontation Clause was violated when the State implicitly conveyed to the jury the content of statements made by deceased witnesses, both through a detective’s testimony and the closing argument of the prosecutor; and (2) these violations were not harmless beyond a reasonable doubt. The Court remanded the case to the superior court for a new trial. View "State v. Roscoe" on Justia Law

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The Supreme Court quashed the judgment of the superior court that granted Defendant’s application for postconviction relief and reinstated Defendant’s convictions, holding that the hearing justice erred in holding that trial counsel rendered ineffective assistance in certain respects. The Supreme Court reinstated Defendant’s conviction with respect to aiding-and-abetting counts for felony murder, robbery, using a firearm in the commission of a crime o violence, discharging a firearm in the commission of a crime of violence, and committing a crime of violence while armed and having available a firearm. Specifically, the Supreme Court held (1) trial counsels’ performance was not deficient in failing to propose aiding-and-abetting jury instructions in line with Rosemond v. United States, 572 U.S. 65 (2014), because that case was inapplicable here; and (2) the hearing justice erred when she held that trial counsel rendered ineffective assistance by failing to challenge the sufficiency of the evidence with respect to an aiding-and-abetting theory. View "Whitaker v. State" on Justia Law

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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

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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

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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

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The Supreme Court affirmed Defendant’s conviction for carrying a firearm without license and other firearm-related offenses. After Defendant filed his appeal, he filed in the Supreme Court a motion to hold the appeal in abeyance and remanded the matter to the superior court to allow him to seek a new trial based on alleged violations of Brady v. Maryland, 373 U.S. 83 (1963). The Court denied Defendant’s motion to hold the appeal in abeyance but granted the remand motion. A hearing on the alleged Brady violation was held before the same justice of the superior court who presided over Defendant’s trial. The trial justice denied both the Brady-related motion for a new trial and Defendant’s motion to recuse the trial justice. The Supreme Court affirmed, holding that the trial justice did not commit prejudicial error by (1) denying Defendant’s motion to suppress two witnesses’ show-up identifications; (2) admitting the recording of an anonymous 911 call at trial; (3) determining that the state did not commit a Brady violation; and (4) denying Defendant’s motion to recuse the trial justice. View "State v. Washington" on Justia Law