Justia Constitutional Law Opinion Summaries

Defendant was charged with ten offenses in a single indictment. After five of the counts were dismissed, the jury returned guilty verdicts on the five remaining counts of first-degree murder, first-degree robbery, and reckless driving, among other crimes. The trial justice sentenced Defendant to life for the murder conviction. The Supreme Court affirmed the judgments of conviction, holding that the trial justice (1) did not err when he did not grant Defendant’s motion to sever the counts relating to the murder/robbery from the counts relating to the police chase; (2) did not err by not granting Defendant’s motion to sever certain offenses committed on one date from offenses committed on another date; (3) did not violate Defendant’s right to a fair trial when he refused to allow a police artist’s sketch into evidence; (4) did not err when he denied Defendant’s motion to exclude three autopsy photographs from evidence; and (5) did not err in denying Defendant’s motion for a new trial. View "State v. Brown" on Justia Law

In the town of Tiverton, two police officers from the Little Compton police department had a discussion with Defendant about a motor-vehicle accident that occurred in Little Compton. The officers then transported Defendant in a police cruiser back to the scene of the accident, where they administered field-sobriety tests, which Defendant failed. Defendant was subsequently charged with driving under the influence of liquor or drugs, among other offenses. Defendant filed a motion to dismiss due to an unlawful arrest, arguing that the officers lacked the authority to arrest him in Tiverton. The trial judge concluded that the arrest was unlawful and dismissed the case. The Supreme Court quashed the judgment of the district court, holding that Defendant was not arrested by the Little Compton police while they were in Tiverton, and therefore, the trial judge erred when she granted Defendant’s motion to dismiss. Remanded. View "State ex rel. Town of Little Compton v. Simmons" on Justia Law

Plaintiffs entered into a loan agreement with Potomac Realty Capital LLC (PRC) to rehabilitate and renovate certain property. As security for the loan, NV One granted a mortgage on the property. Plaintiffs later filed a complaint against PRC, asserting violations of the Rhode Island usury law, among other claims. The trial justice granted summary judgment to Plaintiffs with respect to the usury claim, entered an order declaring the loan usurious and void, and voided the mortgage. At issue on appeal was whether a usury savings clause in the loan document validated the otherwise usurious contract. The Supreme Court affirmed, holding that Plaintiffs were entitled to judgment as a matter of law on their usury claim because (1) the loan was a usury; and (2) the usury savings clause was unenforceable on public policy grounds. View "NV One, LLC v. Potomac Realty Capital, LLC" on Justia Law

Defendant was charged with one count of second-degree sexual assault. A jury trial commenced, but the trial justice granted Defendant’s motion for a mistrial due to a discovery violation. Thereafter, Defendant moved to dismiss the sexual-assault charge on double jeopardy grounds because of prosecutorial goading. The trial justice denied Defendant’s motion. The Supreme Court upheld the trial justice’s denial of Defendant’s motion to dismiss the charge, holding that sufficient evidence in the record supported the trial justice’s finding that the objective facts did not give rise to an inference of intentional goading. View " State v. Rolle" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree child molestation sexual assault. Defendant appealed, contending, among other things, that the trial justice erred when it denied his motion to suppress statements made to police during a post-arrest interrogation. The Supreme Court (1) affirmed the trial justice’s denial of Defendant’s motion for a new trial and discerned no error arising from the justice’s evidentiary rulings; but (2) remanded the case to the superior court with directions to make additional findings of fact and credibility determinations concerning the voluntariness of Defendant’s confessions, as the trial justice failed to make the findings of fact and credibility determinations essential to support his ultimate finding of voluntariness. View "State v. Bojang" on Justia Law

At issue in this case was the Casino Acts, two pieces of legislation providing for the establishment of state-authorized table games at gambling facilities at which Plaintiff, the Narragansett Indian Tribe, received a percentage of income from authorized video lottery terminal (VLT) machines. Plaintiff filed a complaint seeking a declaration that that the Casino Acts were unconstitutional. The superior court concluded that Plaintiff had standing but that Plaintiff failed to meet its burden of proving that the Casino Acts violated the Constitution. Plaintiff appealed, and the State cross-appealed as to the issue of standing. The Supreme Court declined to consolidate the two appeals, and therefore, only the State’s appeal on the issue of standing was before the Court. The Court then affirmed the judgment of the superior court finding that the Tribe was entitled to bring its claims challenging the Casino Act, holding that the reasonable likelihood that the Tribe would suffer a reduction in income from the removal of VLT machines due to the establishment of the table games was sufficient to support a finding that the Tribe had suffered an injury in fact. View "Narragansett Indian Tribe v. State" on Justia Law

Defendant pled nolo contendere to three counts of second-degree child molestation. Before he was sentenced, Defendant filed a motion to withdraw his plea. The trial justice denied the motion and sentenced Defendant to three concurrent sentences of fifteen years at the Adult Correctional Institutions. Eighteen months after sentencing, Defendant filed a motion to vacate judgment and sentence, arguing that his plea to the criminal charges should be set aside because his attorney did not inform him that the attorney was undergoing personal struggles during his representation of Defendant. The Supreme Court affirmed, holding (1) Defendant's appeal was not properly before the court; and (2) even if Defendant's argument was properly made, the argument was without merit. View "State v. Castriotta" on Justia Law

In 1998, Applicant was convicted of first-degree murder and conspiracy to commit first-degree murder. Applicant later filed an application for postconviction relief on the basis of ineffective assistance of counsel. In connection with his application, Applicant filed a subpoena duces tecum seeking discovery of the mental health records of Appellant, who testified as an eyewitness in Applicant's murder trial. Appellant filed a motion to quash the subpoena. The superior court denied the motion. The Supreme Court vacated the order and remanded with directions to make further factual findings, holding that the trial justice erred in ordering the release of Appellant's health care records without first conducting the necessary statutory analysis. View "DePina v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree child molestation and five counts of second-degree child molestation. Defendant appealed, arguing, among other things, that the trial justice erred in admitting evidence that Defendant also allegedly molested the complainant's sister. The Supreme Court affirmed, holding (1) the trial justice did not abuse his discretion in admitting evidence of Defendant's other sexual misconduct; (2) the trial justice did not clearly err in denying Defendant's motion for a new trial; and (3) the trial justice correctly denied Defendant's request for new counsel prior to sentencing. View "State v. Mitchell" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, discharging a firearm while committing a crime of violence, and entering a dwelling with the intent to commit a larceny therein. The convictions were affirmed on appeal. Defendant subsequently filed a motion for a new trial, claiming that newly discovered evidence revealed a cooperation agreement between the police and a prominent state's witness in Defendant's murder trial and that the prosecution violated Defendant's due process rights by failing to disclose the full extent of the agreement. The superior court denied the motion. The Supreme Court affirmed, holding (1) the trial court did not err in finding that the alleged newly discovered evidence failed the first prong of the test to be applied for motions based on newly discovered evidence; and (2) Defendant's due process rights were not violated because the state did not fail to disclose information regarding the cooperation agreement. View "State v. Drew" on Justia Law