Justia Constitutional Law Opinion Summaries

A restaurant owner applied for a liquor license for a property in Providence, Rhode Island. Nearby property owners, including the appellant, filed an objection to the license under a state law that allows such objections to bar issuance of liquor licenses within 200 feet of their property. After the local licensing board could not issue the license due to this objection, the restaurant owner lobbied the General Assembly, which enacted a special law allowing the Providence Board of Licenses to exempt this specific address from the objection rule. This exemption applied only to the property at 225 Waterman Street and was enacted without a vote by local Providence voters.After the special law was passed, the restaurant owner reapplied, and the Board granted the license over objections. The appellant appealed to the Rhode Island Department of Business Regulation (DBR), which stayed the license but did not rule on the constitutional issue. The appellant then filed suit in the Rhode Island Superior Court, arguing that the special exemption was unconstitutional because Article 13, Section 4 of the Rhode Island Constitution requires local voter approval for legislation relating specifically to the property, affairs, or government of a particular city or town. The Superior Court granted summary judgment for the defendants, holding that liquor licensing is a matter of statewide concern and does not require local voter approval.On appeal, the Supreme Court of Rhode Island reviewed the constitutionality of the special law. The court held that the legislation, which singled out a specific property in Providence for exemption from a generally applicable law, related to the property, affairs, and government of a particular city. Because the law did not receive local voter approval as required by Article 13, Section 4, it was void. The Supreme Court vacated the judgment of the Superior Court and remanded for entry of judgment in favor of the appellant. View "Myles Standish Associates, LP v. The City of Providence" on Justia Law

Two men, Jamal Cruz and Rokiem Henley, attended a nightclub in Providence with friends. After the club closed, Cruz had a brief verbal disagreement with two other men, including Terrel Barros and Stephen Bodden. As Cruz and Henley were leaving, Bodden confronted Cruz outside, followed by gunshots that injured Henley and fatally wounded Cruz. Police officers nearby responded quickly, saw Bodden and Barros get into a car, and arrested both men. Barros was subsequently charged and convicted of first-degree murder and several related offenses, largely based on Cruz’s dying identification, eyewitness testimony, and evidence presented at trial.Following his conviction, Barros filed an application for postconviction relief in the Rhode Island Superior Court, alleging several constitutional violations, actual innocence, and the existence of newly discovered evidence. During the postconviction hearing, Barros introduced testimony from Gloria Parajon, Bodden’s cousin, who stated that Bodden had privately confessed to her, on multiple occasions, that he was the shooter. The hearing justice found Parajon’s testimony to be newly discovered, credible, and not merely cumulative, and concluded it could change the verdict at a new trial. The Superior Court granted Barros’s application for postconviction relief and vacated his conviction.On review, the Supreme Court of Rhode Island determined that the Superior Court did not err in admitting Parajon’s testimony as a statement against penal interest under Rule 804(b)(3) of the Rhode Island Rules of Evidence, and that her statements were sufficiently corroborated. The Supreme Court affirmed the judgment of the Superior Court, holding that Barros was entitled to postconviction relief based on newly discovered evidence, and remanded the case for further proceedings. View "Barros v. State of Rhode Island" on Justia Law

Police investigating suspected drug trafficking received information from a confidential informant about two individuals selling drugs. Surveillance linked the suspects to multiple addresses. The investigation included controlled drug buys and installation of a pole camera outside an apartment building. On April 4, 2023, the informant reported a possible deceased person inside one of the apartments. Surveillance footage showed the suspects and another individual entering and exiting the building. Police detained the suspects at a traffic stop and seized keys. Officers then entered the apartment building without a warrant, finding a deceased person in the second-floor apartment and, upon entering the third-floor apartment, discovering drug paraphernalia and contraband.The Providence County Superior Court held a hearing on the defendant’s motion to suppress evidence obtained during the warrantless search and seizure. The trial justice denied the motion, concluding that the police were responding to a sudden emergency involving a possible death and acted rationally to protect citizens from harm and prevent destruction of property. The defendant was subsequently found guilty on all charges following a bench trial and sentenced to twenty-five years, with twenty years to serve and five years suspended. The defendant appealed.The Supreme Court of Rhode Island reviewed the denial of the motion to suppress under the Fourth Amendment and article 1, section 6 of the Rhode Island Constitution, applying the totality of the circumstances standard and deferring to factual findings unless clearly erroneous. The Court held that police had no constitutionally permissible reason to enter the third-floor apartment after finding the deceased in the second-floor apartment and that the exigency justifying entry had evaporated. The Court concluded that the error was not harmless, vacated the conviction, and remanded for a new trial. View "State v. Moronta" on Justia Law

The case centers on the fatal shooting of a seventeen-year-old during a street altercation in Providence, Rhode Island. The defendant was accused of firing a gun at the victim as she approached a fight between her sister and the defendant’s sister. Witnesses saw the defendant shoot in the victim’s direction, after which she collapsed and later died at the hospital. The defendant was apprehended and charged with second-degree murder and two firearms offenses.At the initial trial in the Rhode Island Superior Court, the prosecution exercised a peremptory strike against the only African-American prospective juror. The trial court allowed the strike, accepting the prosecutor’s asserted concern about potential workplace repercussions for the juror. The jury, which had no African-American members, convicted the defendant on the main charges. On appeal, the Rhode Island Supreme Court upheld the conviction, finding the peremptory strike was based on race-neutral grounds. After a habeas petition was denied by the federal district court, the United States Court of Appeals for the First Circuit reversed, holding that the strike was not race-neutral and ordered the state courts to vacate the conviction unless a new trial was held.At the retrial, again only one African-American venireperson was present. The prosecution sought to remove this juror for cause and, when that was denied, exercised a peremptory challenge, citing the juror’s pending criminal cases and lack of candor. The trial justice ultimately allowed the peremptory challenge, and a jury again lacking African-Americans convicted the defendant. The defendant’s motion for a new trial was denied.On appeal, the Supreme Court of Rhode Island held that the trial court failed to properly conduct the third step of the Batson analysis, which requires a probing inquiry into whether the prosecutor’s race-neutral explanation was genuine or pretextual. The court concluded this failure constituted structural error and vacated the conviction, remanding the case for a new trial. View "State v. Porter" on Justia Law

The defendant was indicted for first-degree sexual assault following an incident in March 2021. The complainant testified that she was invited to a social gathering by the defendant, consumed alcohol throughout the night, and later awoke in an unfamiliar motel room unable to move, where she observed the defendant engaging in sexual acts against her will. The complainant denied consenting to sexual activity or going to the motel. A motel employee corroborated that the complainant appeared intoxicated, and forensic testing on her clothing and swabs revealed DNA consistent with the defendant. The defendant conceded to sexual intercourse but claimed it was consensual.The case was tried before the Kent County Superior Court, where a jury heard testimony from the complainant, witnesses, and forensic experts. The laboratory supervisor who reviewed and approved the DNA analysis, but did not perform the testing herself, testified regarding the DNA findings. The defendant moved to strike her testimony, arguing it violated his right to confront the analyst who performed the testing, relying on Supreme Court precedents. The trial justice denied the motion, referencing prior Rhode Island Supreme Court decisions permitting supervisory analysts to testify.On appeal, the Supreme Court of Rhode Island reviewed whether the defendant properly preserved his Confrontation Clause objection and whether an intervening Supreme Court decision, Smith v. Arizona, warranted a departure from the raise-or-waive rule. The Court held that the defendant’s objection was not based on a novel rule of law and was untimely, as prior precedent already addressed the issue. The Court concluded that the intervening decision did not alter existing controlling law and affirmed the Superior Court’s judgment of conviction. View "State v. Vasquez" on Justia Law

In this case, a young woman was fatally shot on a Providence street in August 2021 while standing with her boyfriend beside her parked car. The shooting involved a dark sedan that sped by and fired multiple shots, striking the victim. The case remained unsolved for several months until, in December 2021, police stopped a vehicle for traffic violations. The defendant, seated in the rear, was among the occupants. After observing suspicious behavior and a lowered window in inclement weather, officers retraced the vehicle’s route and found a satchel containing a firearm. Forensic testing later matched the gun to shell casings from the murder scene and identified the defendant as the primary DNA contributor. Investigators also obtained incriminating information from an associate of the defendant, including phone communications linking him to the crime.After the defendant was indicted on multiple charges related to the murder and weapon offenses, he filed pretrial motions in Providence County Superior Court to suppress cell phone records obtained via search warrant and DNA evidence from a buccal swab he had consented to during police questioning. Following an evidentiary hearing, the Superior Court denied both motions. At trial, the jury convicted the defendant of most counts, and the trial justice sentenced him to two consecutive life terms plus additional years. The defendant appealed, arguing that the cell phone warrant lacked probable cause and that his consent to the DNA swab was not voluntary.The Supreme Court of Rhode Island reviewed the case and affirmed the Superior Court’s judgment. It held that the affidavit supporting the cell phone warrant, when considered in totality, established probable cause. It further held that the defendant’s consent to the buccal swab was voluntary under the totality of the circumstances. The court found no constitutional violations and upheld the convictions. View "State v. Pinkerton" on Justia Law

In the early hours of January 24, 2022, the defendant fatally shot one individual and seriously injured another outside a nightclub in Pawtucket, Rhode Island. He did not dispute that he fired the shots, but claimed at trial that he acted in defense of his cousins, whom he believed were in imminent danger after a physical altercation. The incident was captured on video, which at certain points contradicted the defendant’s account. During the trial, the main factual dispute centered on whether the defendant’s use of force was justified under the defense of others doctrine.The case was tried in the Providence County Superior Court. The jury found the defendant guilty of second-degree murder, discharging a firearm during a violent crime resulting in death, and firearm possession offenses, but acquitted him of charges related to the shooting of the second individual. The trial justice sentenced the defendant to a lengthy period of incarceration. During the trial, improper questions from the prosecutor regarding the defendant’s post-arrest silence were objected to and sustained, with the trial justice issuing cautionary instructions to the jury and ultimately denying the defense’s motion for a mistrial.On appeal, the Supreme Court of Rhode Island reviewed whether the trial justice erred in denying a mistrial after the prosecution impermissibly questioned the defendant about his exercise of the right to remain silent. The Supreme Court held that the prosecutor’s questions violated the defendant’s due process rights, as such use of post-arrest silence for impeachment is fundamentally unfair. The Court found that the cautionary instructions did not cure the prejudice resulting from these questions and concluded that a mistrial was warranted. Accordingly, the Supreme Court vacated the conviction and remanded the case for further proceedings. View "State v. Baker" on Justia Law

Two individuals, Nazaski Carrasco-Smith and Devin Delacruz, were shot while sitting in a vehicle in Providence, Rhode Island, on December 4, 2020. Carrasco-Smith survived; Delacruz did not. The investigation led police to a rented Nissan Altima and uncovered connections between the defendant, his girlfriend, and others through surveillance footage, GPS tracking, and extensive cell phone data analysis. Police also discovered a GPS tracker on Carrasco-Smith’s vehicle and recovered incriminating text messages between the defendant and his girlfriend, some of which contained accusations related to the murder.After a grand jury indictment, the case proceeded to trial in the Providence County Superior Court. The state presented forensic and digital evidence as well as expert testimony on local gang rivalries, suggesting a motive. During the trial, the prosecution introduced text messages from the defendant’s girlfriend accusing him of involvement in the murder. The defendant moved to exclude these messages, arguing they were hearsay and unfairly prejudicial. The trial justice denied the motion, admitted the messages, and issued cautionary instructions to the jury. The jury convicted the defendant on all counts, including first-degree murder and multiple firearm offenses. The defendant moved for a new trial, which was denied, and was sentenced to consecutive life terms and additional concurrent sentences.The Supreme Court of Rhode Island reviewed the case. It held that the trial justice abused her discretion by admitting the girlfriend’s accusatory text messages, finding that their probative value was substantially outweighed by their prejudicial effect under Rule 403 of the Rhode Island Rules of Evidence. The court determined that the cautionary instructions given did not cure the prejudice and that the error was not harmless in light of the prosecution’s emphasis on the messages. The court vacated the conviction and remanded for a new trial. View "State v. Chandler" on Justia Law

The plaintiff owned a vacant parcel in Westerly, Rhode Island, and sought to construct a single-family home. To do so, he needed approval from the Department of Environmental Management (DEM) for an onsite wastewater treatment system (OWTS). He applied for a variance from DEM’s regulations, asserting that his proposed system satisfied the general standard for granting variances. However, DEM denied the variance because the property’s water table was at zero inches from the original ground surface, failing to meet a specific regulatory requirement.After DEM’s denial, the plaintiff did not appeal to DEM’s Administrative Adjudication Division (AAD), arguing that such an appeal would be futile since the AAD purportedly lacked discretion to overturn the denial and could not adjudicate constitutional claims. Instead, he filed suit in the Superior Court, seeking declaratory, injunctive, and monetary relief, asserting both as-applied and facial challenges to the OWTS regulations under the Takings, Due Process, and Equal Protection Clauses of the state and federal constitutions. The state moved to dismiss, arguing failure to exhaust administrative remedies and the lack of constitutional violations. The Superior Court granted the state’s motion, finding that the plaintiff failed to exhaust administrative remedies and the futility exception did not apply.On appeal, the Supreme Court of Rhode Island affirmed the Superior Court’s judgment. The Court held that the plaintiff was required to exhaust administrative remedies for his as-applied challenges and that the futility exception did not apply because the AAD had independent authority to grant variances. For the facial constitutional challenge, the Court determined that the complaint failed to state a claim upon which relief could be granted. The judgment dismissing the complaint was affirmed and the matter remanded. View "DiBiccari v. State of Rhode Island" on Justia Law

The plaintiffs purchased undeveloped property in Westerly, Rhode Island, in 1999. In 2007, they applied to the Rhode Island Department of Environmental Management (DEM) for permission to install an onsite wastewater treatment system (OWTS), a prerequisite for building a residence on their land. DEM denied their application because the groundwater table on the property was only five inches below the surface, while regulations required a minimum of twelve inches. The plaintiffs did not pursue an administrative appeal at that time.In 2020, more than a decade after the denial, the plaintiffs filed suit in Washington County Superior Court, seeking declaratory relief and compensation for an alleged regulatory taking under state and federal law. They also asserted that the regulation violated their rights to equal protection and due process. The state moved to dismiss the action, contending it was time-barred, the plaintiffs failed to exhaust administrative remedies, and they lacked standing. The Superior Court agreed, holding that the claims were barred by the statute of limitations, that administrative remedies had not been exhausted, and that the plaintiffs lacked standing. The court dismissed the case with prejudice.On appeal, the Supreme Court of Rhode Island reviewed whether the lower court’s dismissal was proper. The Court held that the three-year statute of limitations applied to all claims, and the continuing violation doctrine did not toll the limitations period because DEM’s denial of the permit was a discrete act, not a continuing violation. The Court further found the plaintiffs lacked standing for prospective relief because they did not allege an actual or imminent injury, as any future application might not necessarily be denied. The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. View "Majeika v. State of Rhode Island" on Justia Law