Articles Posted in Rhode Island Supreme Court

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The Supreme Court affirmed the judgment of the superior court denying Defendant’s application for postconviction relief in which Defendant argued that he had received ineffective assistance of counsel because his lawyer was not licensed to practice law in Rhode Island. Defendant pled nolo contendere to two criminal offenses and admitted to violating his probationary sentence. In his postconviction relief application, Defendant argued that he received ineffective assistance of counsel because his defense counsel, who was not licensed to practice law in Rhode Island, was engaging in unlawful conduct. Defendant further argued that his defense counsel’s associate, who was licensed in Rhode Island and who appeared in court with Defendant, was a “straw man” and thus complicit in the scheme to practice law without a license. The superior court denied the application. The Supreme Court affirmed, holding (1) the trial justice properly found that defense counsel’s associate, not defense counsel, represented Defendant with respect to his pleas; and (2) Defendant’s argument that defense counsel and the associate had a conflict of interest in representing Defendant lacked merit. View "Millette v. State" on Justia Law

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The Supreme Court vacated the judgment of the superior court and remanded this case to the superior court with directions to hear and decide Plaintiff’s motion to amend his complaint upon the merits, holding that the trial justice erred in failing to address Plaintiff’s motion to file a second amended complaint. Plaintiff, an inmate, filed an amended civil complaint alleging negligence on the part of State defendants. Before trial, the trial justice sua sponte raised the issue of the civil death statute in light of Plaintiff’s sentences of life imprisonment. Defendants then filed a motion to dismiss the case under R.I. Gen. Laws 13-6-1, arguing that Plaintiff was deemed civilly dead, and therefore, his civil rights were effectively terminated. Plaintiff then filed a motion for leave to file a second amended complaint seeking to add a claim for violations of Plaintiff’s constitutional rights under color of law. The trial justice granted Defendants’ motion to dismiss based on the civil death statute and did not address Plaintiff’s motion for leave to file a second amended complaint. The Supreme Court held that the trial justice accurately dismissed the case but should have addressed Plaintiff’s second amended complaint before granting Defendants’ motion to dismiss. View "Gallop v. Adult Correctional Institutions" on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of first-degree child molestation sexual assault and one count of the sale or distribution of photographs of a minor suggesting that the minor engaged in, or is about to engage in, a sexual act. On appeal, Defendant argued that the trial court violated his Sixth Amendment right to cross-examine the complaining witness regarding her allegations against her biological father. The Supreme Court disagreed, holding that the trial justice did not abuse his discretion in precluding the admission of this evidence. View "State v. Danis" on Justia Law

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The Supreme Court vacated the decision of the superior court granting Defendant’s motion to suppress statements he made to a Massachusetts Department of Children and Families investigator on grounds that the investigator’s failure to advise Defendant of his right to counsel rendered the statements involuntary. Defendant was indicted by a grand jury on four counts of child molestation. The Supreme Court vacated the decision of the hearing justice granting Defendant’s motion to suppress, holding that, under the circumstances of this case, Defendant’s statements were voluntary, and the motion to suppress should have been denied. View "State v. Gouin" on Justia Law

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The Supreme Court affirmed the judgment of the superior court denying Petitioner’s application for postconviction relief, in which Petitioner claimed that he received ineffective assistance of trial counsel. The Court held (1) Petitioner’s trial counsel was not ineffective for failing to utilize an expert witness on false confessions; (2) the trial justice did not clearly err in refusing to approve funding for the hiring of an expert witness on false confessions in this postconviction relief action; and (3) trial counsel was not ineffective for failing to file a motion to recuse the justice during the trial, and the trial justice did not err in not recusing himself from hearing the instant application for postconviction relief. View "Barros v. State" on Justia Law

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The Supreme Court affirmed the judgment of the superior court granting judgment as a matter of law in favor of Defendants in this employment discrimination action. Plaintiff, a former employee of the Town of Lincoln School Department, filed a complaint against the Town of Lincoln, Lincoln School Committee, and the Town’s Finance Director, alleging that she was discriminated against because she advocated for education services for her disabled son, who was a student in the Lincoln school system. The case went to trial. After both sides rested, the trial justice granted Defendants’ motion for judgment as a matter of law. The Supreme Court affirmed, holding that Plaintiff failed to provide sufficient evidence such that a reasonable jury could find that Lincoln’s actions were retaliation for Plaintiff’s advocacy efforts for her son. View "Azar v. Town of Lincoln" on Justia Law

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The Supreme Court vacated the judgments of conviction entered in the superior court following a jury trial convicting Defendant of three counts of assault with a dangerous weapon and one count of carrying a pistol without a license. The Supreme Court held (1) the superior court justice erred in denying Defendant’s motion to suppress evidence seized by police during a warrantless search of Defendant’s home because the state failed to overcome the presumption of unreasonableness that accompanies every warrantless entry into a home; and (2) the admission of the unlawfully seized evidence was not harmless beyond a reasonable doubt. View "State v. Terzian" on Justia Law

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The Supreme Court affirmed the judgment of the superior court following a jury verdict in favor of Plaintiff on a single claim of employment discrimination based on national origin. Both parties appealed the judgment. The Supreme Court denied and dismissed all appeals, holding that the superior court justice (1) did not err in instructing the jury on the law of evidentiary presumptions and its application to this discrimination claim; (2) properly weighed the evidence and did not invade the province of the jury; and (3) did not err when she vacated the jury’s finding that Plaintiff failed to mitigate his damages. Further, Plaintiff was not entitled to judgment as a matter of law on a separate count in the complaint that also alleged employment discrimination. View "Yangambi v. Providence School Board" on Justia Law

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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