Articles Posted in Rhode Island Supreme Court

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The trial court did not err in declining to suppress the statements Defendant had given tot he police. Defendant was convicted on two counts of first-degree sexual assault. The trial court sentenced Defendant to twenty-five years on both counts, to run concurrently. Defendant appealed the denial of his motion to suppress the statements that he had given to the police, arguing that the State failed to meet its burden of demonstrating, by clear and convincing evidence, that he knowingly, intelligently, and voluntarily waived his constitutional rights under Miranda v. Arizona, 384 U.S. 436 (1966). The Supreme Court affirmed, holding (1) the hearing justice’s finding that Defendant’s statements were not invited by the police but were voluntary statements was correct; (2) Defendant’s post-Miranda statements were admissible because the detectives did not engage in the “question first” interrogation technique found unconstitutional in Missouri v. Seibert, 542 U.S. 600 (2004); and (3) there was no evidence that Defendant failed to comprehend the nature of his rights or the consequences of abandoning them when he made statements while in custody at the police station. View "State v. Sabourin" on Justia Law

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Defendant was charged via a criminal information with breaking and entering a dwelling. After a trial, the trial justice granted Defendant’s motion to pass the case based on based on a comment made by the prosecutor during closing argument. Thereafter, Defendant filed a motion to dismiss the information on grounds of double jeopardy. The trial justice denied Defendant’s motion to dismiss, ruling that the State’s actions were not intended to goad Defendant into seeking a mistrial. The Supreme Court affirmed, holding that the trial justice did not err in determining that the prosecutor did not intentionally goad Defendant into moving for a mistrial. View "State v. Corleto" on Justia Law

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Defendant pleaded nolo contendere to assault in a dwelling house with intent to murder while armed with a dangerous weapon and carrying a pistol on or about his person without a license. While Defendant was on parole, he was arrested and charged with domestic assault and failure to relinquish a telephone. Also while on parole Defendant was charged with breaking and entering. After a hearing, Defendant admitted that he violated the terms and conditions of his probation. Defendant later filed an application for postconviction relief alleging that he was denied the effective assistance of counsel at the probation violation hearing and that he did not knowingly, intelligently, and voluntarily admit a violation of probation. A hearing justice denied Defendant’s application for postconviction relief. The Supreme Court affirmed, holding (1) any alleged deficient performance by Defendant’s attorney was not so prejudicial as to deprive Defendant to a fair trial; and (2) Defendant’s admission was made knowingly, intelligently, and voluntarily. View "Gomes v. State" on Justia Law

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Defendant pled nolo contendere to one count of second-degree sexual assault and one count of intimidation of a witness in a criminal proceeding. Defendant filed an application for postconviction relief alleging that his sentence and conviction were unconstitutional due to the ineffective assistance of counsel. A hearing justice denied postconviction relief, concluding that Defendant made a knowing and intelligent plea at the time of his plea. The Supreme Court affirmed, holding (1) Defendant failed to provide the evidence required to support a claim of ineffective assistance of counsel; and (2) the justice who conducted the postconviction relief hearing did not overlook or misconceive material evidence in arriving at her findings. View "Njie v. State" on Justia Law

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Plaintiff, an attorney employed as a hearing officer for the Rhode Island Department of Elementary and Secondary Education (RIDE), filed a complaint alleging that RIDE and the Rhode Island Board Counsel on Elementary and Secondary Education (collectively, Defendants) violated the Open Meetings Act (OMA) by failing to provide adequate notice of a September 2014 council meeting and by failing to provide any notice of meetings held by the Compensation Review Committee (CRC). The superior court entered summary judgment in favor of Defendants. The Supreme Court reversed in part and affirmed in part, holding (1) Defendants violated the OMA by failing to provide adequate notice of the September 2014 meeting; and (2) the CRC is not a public body and, therefore, is not subject to the OMA. View "Pontarelli v. Rhode Island Board Council on Elementary and Secondary Education" on Justia Law

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Plaintiff was injured on property owned by two individual owners. The unit owners together formed The 18-20 Woodland Court Condominium Association (Defendant). Just prior to the expiration of the relevant three-year statute of limitations, Plaintiff filed a complaint against the individual unit owners, as well as an entity referred to as “XYZ Company.” Nearly an entire year after the expiration of the statute of limitations, Plaintiff sought leave to file an amended complaint in order to add Defendant as a defendant. A hearing justice granted summary judgment in favor of Defendant, concluding that the statute of limitations had run and that Plaintiff’s original complaint had not tolled the statute of limitations because Plaintiff knew of Defendant’s identity at the time she filed the complaint. The Supreme Court affirmed, holding that the statute of limitations on her claim was not tolled pursuant to R.I. Gen. Laws 9-5-20 because Plaintiff knew the identity of Defendant before the statutory period expired. View "Garant v. Winchester" on Justia Law

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In 1994, Applicant entered a plea of nolo contendere to the offense of maintaining a narcotics nuisance. In 2012, Applicant filed a pro se application seeking to vacate his nolo contendere plea. In his application Applicant argued that his plea was not knowing, intelligent, and voluntary and that his counsel provided ineffective assistance. The hearing justice entered judgment for the State and dismissed the application. The Supreme Court affirmed, holding (1) the trial justice did not err in finding that Applicant understood the nature and consequences of his plea; (2) the trial justice properly dismissed Applicant’s claims of ineffective assistance of counsel; and (3) the efforts of postconviction counsel were adequate. View "Reyes v. State" on Justia Law

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Defendant was charged with one count of possession of cocaine. Defendant moved to suppress physical evidence seized and statements made to the police, arguing that he was arrested without probable cause and that the subsequent search of his jacket was unconstitutional. The trial justice denied the motion, determining that police had probable cause to arrest Defendant. After a trial, the jury convicted Defendant of the charged offense. The Supreme Court vacated the judgment of conviction, holding that Defendant’s arrest was not supported by probable cause, and therefore, his motion to suppress should have been granted. View "State v. Ray" on Justia Law

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Defendant was charged with eight counts of first-degree child molestation. Defendant filed a motion to suppress statements he made after his arrest and during his interrogations at the police department, claiming that the statements were coerced and not made voluntarily. The trial justice denied Defendant’s motion to suppress after a hearing. After a trial, the jury returned guilty verdicts on two of the eight counts of first-degree child molestation. Defendant appealed, arguing that the trial justice erred by denying his motion to suppress statements he made to the police during his post-arrest interrogation. The Supreme Court remanded to the superior court for additional fact-finding and credibility determinations. On remand and after a hearing, the trial justice denied Defendant’s motion to suppress his confession. The Supreme Court affirmed, holding that, under the totality of the circumstances, Defendant’s confession was voluntary and was not the product of coercion or impermissible conduct on the part of the interrogating detectives. View "State v. Bojang" on Justia Law

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The Providence Journal Company and Amanda Milkovits (collectively, the Journal) requested records from the Rhode Island State Police concerning an investigation of an underage drinking incident at property owned by the then-Governor Lincoln Chafee. The Rhode Island Department of Public Safety Department denied the Journal’s records request. Thereafter, the Journal filed a complaint against the Department, the State Police, and the Commissioner of the Department (collectively, Defendants) alleging violations of Rhode Island’s Access to Public Records Act (APRA). The superior court granted summary judgment to Defendants, concluding that the requested documents were not subject to public disclosure pursuant to the APRA. The Supreme Court affirmed, holding that the records request was properly denied pursuant to the APRA. View "Providence Journal Co. v. R.I. Dep’t of Pub. Safety" on Justia Law