Justia Constitutional Law Opinion Summaries

Defendant Julie Robat appealed her conviction on one count of second-degree murder. The victim was Defendant's newborn daughter. On appeal, Defendant contended that the trial justice erred in failing to grant her motion for a judgment of acquittal and her later motion for a new trial on a second-degree murder charge; the basis for that contention was Defendant's underlying assertion that the state failed to provide legally sufficient evidence for a jury to find that she acted with malice in connection with the death of her baby. Furthermore, Defendant contended that the trial justice erred in failing to grant her motion for a new trial because of what she alleged were improper comments made by the prosecutor during her closing argument. Upon review of the trial court record, the Supreme Court found no merit to Defendant's contentions on appeal, and affirmed her conviction.

Defendant James S. Richardson appealed his conviction by jury of first degree murder and burglary charges for which he was sentenced to life imprisonment without the possibility of parole. On appeal, Defendant argued that his conviction should have been vacated because the trial justice impermissibly allowed an expert witness called by the state to bolster the testimony of another of the state's expert witnesses. He also argued that the trial justice erred when he denied his motions for judgment of acquittal and for a new trial. Upon review of the trial court record, the Supreme Court affirmed the judgment of conviction.

Applicant Eddy Guerrero appealed the denial of his application for postconviction relief. His sole contention on appeal was that the hearing justice erred in holding that his trial counsel provided effective assistance of counsel prior to and during Applicant's plea of nolo contendere. Specifically, Applicant contended: (1) that his counsel failed to obtain an interpreter for him at the time of the hearing on his motion to suppress certain evidence and at the time of his eventual plea; (2) that, prior to his execution of the plea form, his counsel failed to properly explain to him the essential elements of the offense to which he ultimately pled nolo contendere; (3) that his trial counsel failed to meet with him in a setting conducive to meaningful attorney-client communications; (4) that, by not conducting a sufficient investigation, his counsel failed to properly prepare for the suppression hearing; and (5) that the hearing justice erred in failing to address the prejudice component of the analysis relative to ineffective assistance of counsel allegations that is described in "Strickland v. Washington," (466 U.S. 668 (1984)). Upon review, the Supreme Court found none of Applicant's arguments on appeal to have merit, and affirmed the superior court's judgment.

The issue before the Supreme Court in this petition was whether G.L. 1956 section 5-6-2 permits only licensed electricians to install underground hollow polyvinyl chloride (PVC) material that is devoid of any electrical wiring or conductors. The Board of Examiners of Electricians, the Rhode Island Department of Labor and Training (DLT), and the Superior Court all determined that 5-6-2 required a licensed electrician to perform such work. The petitioners, Reilly Electrical Contractors, Inc. (Relco), Michael McSheffrey, Robert Rutledge, John Brewer, and Ray Bombardier, disagreed and petitioned the Court for a writ of certiorari. Upon review of the statute at issue here, the Court affirmed the judgment of the Superior Court.

At the end of a trial held in Kent County Superior Court, a jury found the defendant, James Cook guilty of twenty-two counts ranging from first-degree sexual assault to identity fraud. On appeal, defendant contended that the trial justice committed reversible error in denying his motion for a mistrial after the jury heard testimony that he had been on probation and also in admitting evidence of other prior sexual misconduct. Finding no error nor abuse of discretion, the Supreme Court affirmed the judgment of the Superior Court.

Defendant, Kenneth Viveiros appealed his conviction on four counts of simple assault against three inmates at the Adult Correctional Institutions (ACI), occurring while the defendant was employed as a lieutenant at the ACI. On appeal, defendant asserted that the trial justice: (1) abused his discretion in denying defendant's motion to sever his trial from that of his codefendant, Captain Gualtar Botas; (2) abused his discretion in granting the state's motion in limine, precluding defense testimony from an inmate; (3) erred by giving improper jury instructions; and (4) erred in denying defendant's motion for a new trial based on the insufficiency of the evidence. Upon thorough review, the Supreme Court affirmed defendant's convictions.

Plaintiff Roderick McGarry appealed a final judgment in favor of Defendant Town of Cumberland School Department which granted defendant's motion for judgment as a matter of law. The trial justice concluded that plaintiff failed to present sufficient evidence that defendant had discriminated against him on the basis of his age. After a jury trial, the verdict was returned in plaintiff's favor. However, the trial justice granted defendant's motion for judgment as a matter of law. On appeal to the Supreme Court, plaintiff contended the trial justice's post-trial Rule 50 ruling was in error and argued that the jury verdict should be reinstated. Specifically, plaintiff contended that the trial justice erred by granting judgment as a matter of law because: (1) defendant failed to offer a nondiscriminatory reason for not hiring plaintiff; and (2) the trial justice erred in ruling that an adverse inference resulting from the spoliation of evidence, without additional extrinsic evidence, could not satisfy plaintiff's burden of proof (plaintiff contended that he did present such extrinsic evidence). Upon review, the Supreme Court partly affirmed the superior court, and partly reversed. The Court found the trial justice erred in granting defendant's motion for judgment as a matter of law, finding plaintiff presented sufficient evidence to make a prima facie case of discrimination. The Court agreed with the trial justice in granting defendant's motion for a new trial. The case was remanded to the superior court for further proceedings.

Defendant Brown University appealed a Superior Court judgment in favor of Plaintiff Beverly Haviland in her action for declaratory relief. The issue arose over placement of Haviland in a tenured teaching position as a condition to the employment contract her husband, another tenured professor would receive. The husband would not accept a position with Brown unless the university made room for his plaintiff. Through a series of letters ad negotiations, plaintiff accepted Brown's offer of employment. When her contract was due for renewal, issues arose over promises made in those letters and negotiations that became the subject of this dispute. Brown contended that there was no justiciable issue in this case because plaintiff could not demonstrate an injury in fact, as she did not face any actual or imminent loss of employment. Brown also asserted that the trial justice erred in determining the existence of an implied-in-fact contract between the plaintiff and Brown because insufficient evidence was presented to establish an enforceable promise of de facto tenure. Further, Brown contended that no tenure-like standard of review applied to plaintiff because only the Brown Corporation was vested with the authority to grant tenure and none of the University administrators who communicated with plaintiff were vested with actual or apparent authority to provide the plaintiff with de facto tenure. Upon review, the Supreme Court rejected Brown's arguments and affirmed the Superior Court's judgment in this case.

Plaintiff Laurel Y. Hazard appealed the grant of a motion for summary judgment in favor of the defendant, East Hills, Inc., declaring that the plaintiff was barred by the doctrine of laches from prosecuting a claim of ownership to an undeveloped eight-acre tract of land in South Kingstown, Rhode Island and finding that the defendant had established ownership of the tract of land by adverse possession and in accordance with the Rhode Island Marketable Record Title Act. On appeal, plaintiff asserted that her claim should not have been barred by the doctrine of laches, that the defendant failed to satisfy the requisite elements of adverse possession of the subject property, and that a 1909 boundary agreement entered into by the defendant's predecessor in interest was defective and was improperly relied upon by the special master as a title transaction for purposes of establishing marketable record title. Upon review of the record, the Supreme Court affirmed, finding no error in the trial justice's conclusion that defendant proved the requisite elements of the complete-defense of laches, and therefore did not reach plaintiff's subsequent issues.

Defendant Raymond McWilliams was found guilty on one count of first-degree robbery and one count of assault with a dangerous weapon. In light of his "impressive" criminal history, the trial justice sentenced him to life in prison for first-degree robbery, to be served consecutively to eleven-and-one-half years that previously had been executed because he violated probation on a previously imposed sentence on a prior second-degree murder conviction. Defendant was also sentenced to life in prison for the conviction for assault with a dangerous weapon, to be served consecutively to the sentence imposed for the robbery and the previously imposed probation-violation sentence. Because he qualified as a habitual offender the trial justice imposed an additional ten years imprisonment to run consecutively to the previously imposed sentences. On appeal to the Supreme Court, Defendant asserted that the trial justice erred by: (1) providing a supplemental jury instruction that contradicted Rhode Island law; (2) refusing to recuse from presiding as the trial justice because of comments he had made during a joint probation-violation hearing and bail hearing; (3) admitting into evidence defendant's prior conviction for second-degree murder; (4) denying his motion for acquittal; and (5) denying his motion for a new trial. After review, the Court concluded that Defendant's arguments were without merit, and affirmed the judgment of the Superior Court.