Justia Civil Rights Opinion Summaries

Following a jury trial, Defendant Gilbert Delestre was found guilty of second-degree murder and of conspiracy to commit the offense of murder. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not err in (1) instructing the jury concerning the concept of aiding and abetting, as the instruction considered in its entirety did not relieve the State of its burden and did not violate Defendant's due process rights; and (2) declining to give a unanimity instruction to the jury with respect to the murder charge, as the jury was not required to unanimously agree as to whether Defendant was guilty of second-degree murder as a principal, as an aider or abettor, or as a coconspirator.

Defendant Giulio Lancellotta pled nolo contendere to second-degree robbery and was sentenced to twelve years in prison, which sentence was suspended, and twelve years probation. A magistrate later found that Defendant had violated his probation and sentenced him to serve seven years of his twelve-year suspended sentence. The Supreme Court affirmed, holding (1) the magistrate did not abuse his discretion when he denied Defendant's motion for new counsel; (2) the magistrate did not act arbitrarily or capriciously when he found that the evidence presented at the probation-violation hearing was sufficient to demonstrate that Defendant had violated his probation; and (3) the magistrate acted within his discretion in imposing the sentence.

Defendant was convicted of domestic first-degree sexual assault and domestic assault with intent to commit sexual assault. The Supreme Court affirmed, holding that the trial justice did not abuse her discretion by (1) refusing to pass the case after the complainant testified that the police issued to her a no-contact order against Defendant because (i) the testimony was not sufficiently prejudicial as to prevent the jury from calmly and dispassionately considering the evidence, (ii) the trial justice's cautionary instructions alleviated any prejudicial impact of the testimony, and (iii) the jury's final verdict suggested that the testimony did not inflame the passions of the jurors to the point where they were unable to pass impartially upon the issues in the case; and (2) denying a second motion to pass the case when a police officer, while testifying, improperly bolstered the complainant's credibility because the improper bolstering was not sufficiently prejudicial to Defendant.

Appellant Craig Quigley was a beneficiary of a testamentary trust. In 2003, the trustees filed a petition in the superior court to reform the trust. The court entered an order granting the petition. In 2009, Quigley filed a motion to vacate the order, arguing (1) that the superior court had never obtained jurisdiction over Quigley because there was no service of process with respect to the petition and, therefore, any judgment against Quigley was void; and (2) the order should be vacated pursuant to R.I. Sup. Ct. R. 60(b)(6), which provides for vacation of any order for "any other reason justifying relief." The hearing justice denied the motion. Quigley appealed. The Supreme Court affirmed, holding (1) because Quigley was not a defendant in the proceeding with respect to the petition for reformation of the trust, service of process was not required; (2) because Quigley had actual notice of the proceeding and was represented by counsel at the proceeding, Quigley's due process rights were not violated; and (3) the Rule 60(b)(6) motion was not made within a reasonable time in violation of the rule.

Defendant James Enos dated Mary for six months before they separated. After their separation they met at a restaurant where defendant began swearing at Mary. Defendant then hit Mary on the head with drinking glasses and kicked her. Defendant was convicted of domestic assault with a dangerous weapon. Defendant appealed, arguing (1) that the evidence presented by the state was legally insufficient for a reasonable juror to conclude that defendant and Mary were in a domestic relationship; and (2) the trial justice erred when she refused to declare a mistrial after a police officer testified that after defendant was informed of his Miranda rights defendant remained silent. The Supreme Court affirmed, holding (1) the evidence, overall, indicated that defendant and Mary were in a substantive dating relationship and therefore the trial justice correctly denied defendant's motion for a judgment of acquittal; and (2) the trial justice was not clearly wrong when she denied the defendant's motion for a mistrial and instead opted to instruct the jury to disregard the officer's unsolicited remark.

Plaintiff Kathy Lamarque executed a mortgage with defendant Centreville Savings Bank. After defaulting on another loan for a second mortgage on the same property, defendant disclosed the balance of plaintiff's mortgage to the purchaser of plaintiff's property at a foreclosure sale. Plaintiff filed a complaint against defendant for negligence and a violation of plaintiff's privacy rights. At trial, defendant moved for a judgment on partial findings, which the trial court granted. Plaintiff appealed, arguing that her right to privacy was violated by defendant and that the Gramm-Leach-Bliley Act and defendant's privacy policy created a legal duty to protect private information from disclosure. The Supreme Court affirmed, holding that under the facts of the case, plaintiff's privacy rights were not violated and defendant did not breach its duty to plaintiff.

In 2006, defendant Edgar Goulet killed his dog by shooting it with a sawed-off shotgun. One year later, the state, by way of criminal information, charged defendant with one count of malicious killing of an animal and one count of possession of a sawed-off shotgun. At trial, among other motions, defendant filed a motion to sever to the two counts of the information. The motion to sever was denied. After a jury trial defendant was convicted on both counts. The defendant appealed. The issues properly before the Supreme Court were (1) defendant's assertion that the trial justice erred when he denied defendant's motion to sever, and (2) the defendant's Fourth Amendment claims relating to the police officers' searches of the defendant's yard and home. The Court affirmed, concluding (1) the defendant did not make a sufficient showing that he would be prejudiced to the extent that he would not receive a fair trial if the two counts were not severed, and thus the trial justice did not abuse his discretion when he denied defendant's motion; and (2) the defendant's Fourth Amendment claims as to the propriety of the warrantless search were without merit.

Plaintiff Horton appealed from a superior court grant of summary judgment in favor of the police department defendants, dismissing the plaintiff's thirteen-count complaint which alleged, among other complaints, malicious prosecution, false arrest, false imprisonment, tortious denial of access to public records, violations of civil rights, and failure to destroy records after exoneration. The Supreme Court affirmed, holding (1) defendants possessed probable cause for each instance of prosecution, arrest, and imprisonment, making a grant of summary judgment appropriate; and (2) because Horton failed to provide analysis of the remaining questions in his appeal, those contentions were deemed waived for appellate review.

Plaintiff Walter Moore appealed a grant of summary judgment in favor of the Defendants, the Rhode Island Board of Governors for Higher Education (Board of Governors) and the University of Rhode Island (URI). Plaintiff brought an employment discrimination suit against the Defendants in 2008, and in that suit, the record revealed that Plaintiff executed a waiver and release in which he released Defendants from liability for any lawsuits that arose from his employment with the Board of Governors. Plaintiffâs claim was then dismissed in the lower court. On appeal, the issue before the Supreme Court was whether that waiver-and-release applied to the URI as an agent of the Board of Governors. After reviewing the case records, the Supreme Court was not satisfied that the record reflected the waiver applied to the URI. The Court vacated the judgment of the lower court and remanded the case for further fact-finding proceedings.