Justia Constitutional Law Opinion Summaries

Articles Posted in Rhode Island Supreme Court
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The case involves Marklyn Brown, who was arrested and indicted for a shooting that resulted in the death of Ms. Berta Pereira-Roldan. During his seven-hour interrogation at the Providence Police Department, Brown consistently maintained his innocence and expressed his desire to speak with his mother. After three hours of questioning, the police allowed Brown to speak with his mother. The conversation between Brown and his mother was recorded and listened to by the police without their knowledge.The Superior Court heard Brown's motions to suppress the statements he made during the interrogation and the recorded conversation with his mother. Brown argued that his Fifth Amendment right against self-incrimination, his Sixth Amendment right to counsel, and his right under article 1, section 13 of the Rhode Island Constitution against self-incrimination were violated. He also argued that the surreptitious recording violated the Fourth Amendment to the United States Constitution, the Rhode Island Constitution, and constituted an unauthorized wiretap pursuant to G.L. 1956 § 11-35-21. The trial justice suppressed both the interrogation and Brown's entire conversation with his mother, determining that Brown had a reasonable expectation of privacy when he spoke to his mother in the interview room.The Supreme Court of Rhode Island affirmed the order of the Superior Court. The court concluded that Brown had a reasonable expectation of privacy when he spoke with his mother in the interview room, and that the police violated Brown's Fourth Amendment rights as well as his rights pursuant to article 1, section 6 of the Rhode Island Constitution when they recorded his conversation with his mother. The court rejected the state's arguments that Brown did not possess a reasonable expectation of privacy because he did not ask for a private, unrecorded conversation, and that he lacked a reasonable expectation of privacy in a police interrogation room. View "State v. Brown" on Justia Law

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The defendant, Victor Tavares, was convicted by a jury on two counts of first-degree sexual assault and one count of conspiracy to commit first-degree sexual assault. The charges stemmed from an incident that occurred at a party in 2012, where Tavares and another man, Franklin Johnson, were accused of sexually assaulting a woman named Mary. The evidence against Tavares included Mary's testimony, a used condom found at the scene, and DNA evidence linking Johnson to the condom. Tavares, who represented himself at trial and on appeal, raised twelve issues for consideration.Before the Supreme Court of Rhode Island, Tavares argued that the trial court erred in several ways, including by not dismissing the indictment based on the rule of consistency, the doctrine of collateral estoppel, and the General Assembly's lack of authority to enact criminal laws. He also claimed that the trial court improperly conducted voir dire and allowed the introduction of Johnson's DNA evidence.The Supreme Court rejected all of Tavares's arguments. It held that the trial court properly conducted voir dire and correctly allowed the introduction of Johnson's DNA evidence. The court also found that the General Assembly had the authority to enact the criminal laws under which Tavares was charged and convicted. Furthermore, the court ruled that the doctrines of collateral estoppel and the rule of consistency did not apply in this case. Therefore, the Supreme Court affirmed Tavares's conviction. View "State v. Tavares" on Justia Law

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The Supreme Court vacated the orders of the superior court granting Defendants' motions to suppress evidence of approximately ninety-four pounds of marijuana seized from one defendant's vehicle during a traffic stop, holding that the trial justice erred in granting Defendants' motions to suppress.Junjie Li was operating a vehicle and Zhong Kuang was in the passenger seat when a law enforcement officer initiated a traffic stop. While conversing with Li, the officer noticed Li began to exhibit nervous behavior and detected an order of marijuana coming from inside Kuang's vehicle. After a dog sniff, officers discovered marijuana. Li and Kuang moved, individually to suppress the marijuana. The trial justice granted the motions to suppress, holding that the extension of the traffic stop beyond its original scope was unreasonable because the officer did not have independent reasonable suspicion to prolong the stop. The Supreme Court vacated the superior court's orders, holding that the trial justice erred in concluding that the officer did not possess reasonable suspicion to prolong the stop based on the totality of the circumstances. View "State v. Li" on Justia Law

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The Supreme Court affirmed the orders of the superior court granting motions to suppress filed by Defendants Jerome Joseph and Voguel Figaro, holding that the hearing justice did not err in granting Defendants' suppression motions.Figaro moved to suppress physical evidence seized as the result of a motor vehicle stop, arguing that the officer unconstitutionally prolonged the stop to perform a dog sniff. Joseph also filed a motion to suppress and joined the memorandum supporting Figaro's suppression motion. The hearing justice granted the motions to suppress, holding that reasonable suspicion did not support the prolonged traffic stop of Figaro's vehicle. The Supreme Court affirmed, holding that the hearing justice properly found that the state police lacked reasonable suspicion to detain Defendants. View "State v. Joseph" on Justia Law

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The Supreme Court quashed the order of the district court granting the motion to dismiss filed by the State of Rhode Island, acting by and through the Division of Taxation (Division), in this appeal stemming from a series of transactions for the purchase and sale of gasoline, holding that the district court erred in granting the Division's motion to dismiss based on Plaintiff's failure to exhaust its administrative remedies.The tax at issue was levied on a transaction between Plaintiff and another party and was the subject of several transactions between various entities. Plaintiff reimbursed a third-party for the tax assessed on the sale of 300,000 barrels of gasoline and then initiated this action alleging constitutional violations and violations of the Motor Fuel Tax. The trial judge dismissed the case for Plaintiff's failure to exhaust administrative remedies. The Supreme Court reversed, holding that the trial judge erroneously dismissed the action based on Plaintiff's failure to exhaust its administrative remedies. View "Gunvor USA, LLC v. State, ex rel. Division of Taxation" on Justia Law

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The Supreme Court quashed the order of the district court dismissing two actions challenging the State Division of Taxation's denial of Plaintiff's claim for a refund of $4,280,039 paid for Motor Fuel Tax assessed on the purchase and sale of 300,000 barrels of gasoline, holding that the the district court erred.Plaintiff purchased 300,000 barrels of gasoline from Defendant. The Division imposed a motor fuel taxes on the gasoline that was charged to Defendant, as the seller of the gas. Defendant sought reimbursement from Plaintiff, which sought a refund from the Division under R.I. Gen. Stat. 31-36-13. The Division denied Plaintiff's claim for a refund on the grounds that Plaintiff did not have a right to pursue a refund. Plaintiff then filed a complaint alleging constitutional violations and violations of the Motor Fuel Tax, among other claims. Plaintiff then appealed the Division's denial of its request for a refund. The hearing officer concluded that Plaintiff's claim was barred by both res judicata and administrative finality. Ultimately, both cases were dismissed. The Supreme Court quashed the decisions below, holding (1) Plaintiff had standing; (2) the trial judge erred in concluding that res judicata barred Plaintiff's appeal; and (3) the doctrine of administrative finality did not apply to bar Plaintiff's claims. View "Apex Oil Co. v. State, ex rel. Division of Taxation" on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of three counts of first-degree sexual assault, following a jury trial, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme eCourt held that the trial justice (1) did not violate Defendant's constitutional right to present a defense by excluding the proposed expert testimony of Dr. Patricia R. Recupero as not relevant under Rule 401 of the Rhode Island Rules of Evidence; (2) did not err in instructing the jury that there was no need for certain testimony to be corroborated in order to support a guilty verdict; and (3) did not abuse his discretion in limiting the redirect examination of Defendant about his preparation for trial. View "State v. Robinson" on Justia Law

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The Supreme Court affirmed in part and vacated in part the amended judgment of the superior court in favor of Plaintiff, as executor of the Estate of Armando Damiani (Mandy) and the Estate of Lillian Estrella, in this action alleging that Defendants had conspired to commit an unlawful conversion of funds in Mandy's investment account, holding that the portion of the amended judgment awarding Plaintiff compensatory damages and prejudgment interest was error.Specifically, the Supreme Court held (1) the trial justice erred by permitting a witness to testify despite knowing that she would invoke her privilege against self-incrimination under the Fifth Amendment, and the error prejudiced Defendant; and (2) there was no reason to disturb the trial justice's decision on Plaintiff's claim for declaratory judgment. View "Estrella v. Janney Montgomery Scott LLC" on Justia Law

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The Supreme Court affirmed the judgments of the superior court convicting Defendant following a jury trial for larceny of an automobile and adjudicating him a probation violator, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued, among other things, that the trial court erred in denying his motion to suppress certain evidence collected as a result of a warrantless search of his real-time cell-site location information (CSLI). The Supreme Court disagreed and affirmed, holding (1) the acquisition of real-time CSLI qualifies as a search under the Fourth Amendment for which a warrant is required; (2) any error in the trial justice's determination that the exigent circumstances exception to the warrant requirement applied to the facts of this case was harmless; (3) the trial justice did not abuse his discretion in denying Defendant's motion to exclude certain testimony, and any error in allowing other testimony to be admitted at trial was harmless; and (4) Defendant waived his last argument for appeal. View "State v. Sinapi" on Justia Law

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The Supreme Court affirmed the judgment of the superior court in granting summary judgment in favor of Defendants, Rhode Island College and related individuals, on the grounds of qualified immunity, holding that Plaintiff was not entitled to relief on his claims of error.Plaintiff brought this action seeking equitable relief and damages under 42 U.S.C. 1983 and 1988 on the grounds that Defendants' conduct toward him during his Master of Social Work program violated his First and Fourteenth Rights. The superior court concluded that Defendants were entitled to qualified immunity and granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding that Plaintiff's arguments on appeal were unavailing. View "Felkner v. R.I. College" on Justia Law