Justia Civil Rights Opinion Summaries

Articles Posted in Rhode Island Supreme Court
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The Supreme Court affirmed the order of the superior court granting Defendants' motion to dismiss all electronic, wire, or oral communications obtained through the use of wiretaps and any subsequently-obtained evidence in these consolidated cases, holding that the trial justice did not err.In granting Defendants' motion to suppress, the trial justice found that an associate justice of the superior court had no authority to issue the wiretap orders. The State appealed this ruling and argued, alternatively, that the trial justice erred in concluding that suppression of the evidence derived from the wiretap orders was warranted. The Supreme Court affirmed, holding that the trial court correctly concluded that the associate justice was not vested with the statutory authority to administer and sign the wiretap orders and, therefore, that those orders were in violation of R.I. Gen. Laws 12-5.1, the Interception of Wire and Oral Communications Act. View "State v. McGuire" on Justia Law

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The Supreme Court affirmed the judgment of the superior court dismissing Plaintiffs' claims based on lack of standing, holding that there was no error.In 2019, the General Assembly enacted the Reproductive Privacy Act, R.I. Gen. Laws chapter 4.13 of title 23 (RPA), effectively granting a right to abortion in line with Roe v. Wade. 410 U.S. 113 (1973). Plaintiffs initiated this action seeking to halt the passage of House Bill 5125, Substitute B, which later became the RPA. The trial justice denied relief. Plaintiffs then filed a complaint challenging the General Assembly's authority to enact the RPA. The trial court granted Defendants' motion to dismiss for failure to state a claim. The Supreme Court affirmed, holding that Plaintiffs lacked standing to bring their claims. View "Benson v. McKee" on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree murder, first-degree robbery, and other crimes, holding that Defendant was not entitled to relief on her allegations of error.On appeal, Defendant argued that the trial justice erred in denying her motion to suppress the evidence found at her apartment, denying her motion to suppress the evidence found in her vehicle, and violating her right to confront a witness. The Supreme Court affirmed, holding (1) there was no error in the trial justice's denial of Defendant's motion to suppress the evidence obtained in the apartment based on insufficient probable cause; (2) the trial justice did not clearly err in denying Defendant's request for a Franks hearing; (3) the warrantless seizure of Defendant's vehicle did not violate her rights under either the State or Federal Constitution; and (4) Defendant's Confrontation Clause argument was waived. View "State v. Hudgen" on Justia Law

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The Supreme Court affirmed the final judgment of the superior court in favor of Defendants due to Plaintiff's having failed to comply with her discovery obligations, which had earlier been the subject of a conditional order of dismissal, holding that there was no error.Plaintiff brought this complaint alleging that Defendants had discriminated against her in retaliation for her whistleblowing activities and that she was entitled to relief under the Rhode Island Whistleblowers' Protection Act. Ultimately, the hearing justice granted Defendants' motion for final judgment on the grounds that Plaintiff had, over a five-year period, repeatedly failed to comply with her discovery obligations. The Supreme Court affirmed, holding that the hearing justice acted within her discretion in ordering the entry of final judgment. View "Boss v. Chamberland" on Justia Law

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In this action for declaratory judgment the Supreme Court reversed the judgment of the superior court denying Family Dollar Stores of Rhode Island, Inc.'s motion for summary judgment and granting summary judgment for Justin Araujo, the complainant in a proceeding before the Rhode Island Commission for Human Rights, holding that the hearing justice erred.Araujo filed a complaint with the Commission alleging that Family Dollar, his employer, had discriminated against him on the basis of an illness. The parties entered into a settlement agreement that included a release. At issue was whether the release unambiguously constituted a waiver by Araujo of his right to pursue all claims he could make against Family Dollar. The hearing justice granted summary judgment in favor of Araujo, entering judgment declaring that the release did not cover Araujo's discrimination claims. The Supreme Court reversed, holding that the release unambiguously precluded Araujo from pursuing a discrimination charge with the Commission. View "Family Dollar Stores of Rhode Island, Inc. v. Araujo" on Justia Law

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In these consolidated appeals, the Supreme Court held that Rhode Island's civil death statute, R.I. Gen. Laws 13-61-1, is unconstitutional and in clear contravention of the provisions of R.I. Const. art. I, 5.Plaintiffs, Cody-Allen Zab and Jose R. Rivera, were two inmates serving sentences of life imprisonment. Plaintiff brought this action against Defendants, the Rhode Island Department of Corrections and its director and Global Tel*Link Corporation, asserting that while they were imprisoned they incurred injuries due to Defendants' negligence. The hearing justice concluded that the civil death statute barred Plaintiffs' negligence claims and that Zab's 42 U.S.C. 1983 federal claim failed as a matter of law. The Supreme Court reversed in part, holding that the civil death statute unconstitutionally denied Plaintiffs the right to gain access to the courts. View "Zab v. R.I. Department of Corrections" on Justia Law

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The Supreme Court affirmed Defendant's conviction of one count of first-degree robbery and other firearm-related offenses, holding that there was no error in the proceedings below.On appeal, Defendant argued that the trial court erred in refusing to instruct the jury on cross-racial identification and that he was denied his right to due process when the trial court denied his motion to dismiss the State's habitual offender notice. The Supreme Court affirmed, holding (1) the trial justice did not err or abuse his discretion in failing to give Defendant's requested instruction regarding cross-racial identifications; and (2) the trial justice did not err in denying Defendant's motion to dismiss the State's habitual offender notice as untimely under R.I. Gen. Laws 12-19-21. View "State v. Hampton-Boyd" on Justia Law

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The Supreme Court affirmed the judgment of the superior court dismissing Plaintiff's complaint against Defendants - Brown University and two of its officials - seeking damages and equitable relief arising out of Defendants' response to Plaintiff's sexual assault allegations, holding that the trial court did not err.Plaintiff brought his suit pursuant to the Rhode Island Civil Rights Act, chapter 112 of title 42 of the general laws (RICRA) and article 1, section 2 of the Rhode Island Constitution. The hearing justice granted Defendants' motion to dismiss for failure to state a claim, concluding that issue preclusion foreclosed the claims under RICRA based on a previous decision of the federal courts and that article 1, section 2 did not grant Plaintiff a private right of action. The Supreme Court affirmed, holding that the hearing justice did not err in dismissing Plaintiff's complaint. View "Doe v. Brown University" on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of five counts related to conduct stemming from a drive-by shooting, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) there was no need to reach the merits of Defendant's belatedly raised double jeopardy contention; (2) the trial justice did not err in denying Defendant's motion to suppress an eyewitness identification; (3) the trial justice did not err by summarily denying Defendant's motion to recuse; (4) Defendant was not denied his constitutional right to self-representation; and (5) Defendant's remaining arguments were not properly preserved for appellate review. View "State v. Segrain" on Justia Law

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The Supreme Court vacated the judgment of the family court convicting Defendant of cruelty to or neglect of a child and sentencing her to a one-year suspended term of imprisonment, with probation, holding that a new trial was required.On appeal, Defendant argued that the trial justice erred by proceeding with a bench trial without obtaining a knowing, intelligent, and voluntary waiver of Defendant's right to a jury trial and erred in finding habitual neglect in this case. The Supreme Court vacated the judgment below, holding that because there was nothing in the record indicating that the trial justice was assured by Defendant that her waiver of a jury trial was made intelligently and with full knowledge of the consequences of her waiver, the case must be remanded for a new trial. View "State v. Michaud" on Justia Law