Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed the judgment of the superior court dismissing Plaintiffs' claims based on lack of standing, holding that there was no error.In 2019, the General Assembly enacted the Reproductive Privacy Act, R.I. Gen. Laws chapter 4.13 of title 23 (RPA), effectively granting a right to abortion in line with Roe v. Wade. 410 U.S. 113 (1973). Plaintiffs initiated this action seeking to halt the passage of House Bill 5125, Substitute B, which later became the RPA. The trial justice denied relief. Plaintiffs then filed a complaint challenging the General Assembly's authority to enact the RPA. The trial court granted Defendants' motion to dismiss for failure to state a claim. The Supreme Court affirmed, holding that Plaintiffs lacked standing to bring their claims. View "Benson v. McKee" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree murder, first-degree robbery, and other crimes, holding that Defendant was not entitled to relief on her allegations of error.On appeal, Defendant argued that the trial justice erred in denying her motion to suppress the evidence found at her apartment, denying her motion to suppress the evidence found in her vehicle, and violating her right to confront a witness. The Supreme Court affirmed, holding (1) there was no error in the trial justice's denial of Defendant's motion to suppress the evidence obtained in the apartment based on insufficient probable cause; (2) the trial justice did not clearly err in denying Defendant's request for a Franks hearing; (3) the warrantless seizure of Defendant's vehicle did not violate her rights under either the State or Federal Constitution; and (4) Defendant's Confrontation Clause argument was waived. View "State v. Hudgen" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of first-degree robbery and other firearm-related offenses, holding that there was no error in the proceedings below.On appeal, Defendant argued that the trial court erred in refusing to instruct the jury on cross-racial identification and that he was denied his right to due process when the trial court denied his motion to dismiss the State's habitual offender notice. The Supreme Court affirmed, holding (1) the trial justice did not err or abuse his discretion in failing to give Defendant's requested instruction regarding cross-racial identifications; and (2) the trial justice did not err in denying Defendant's motion to dismiss the State's habitual offender notice as untimely under R.I. Gen. Laws 12-19-21. View "State v. Hampton-Boyd" on Justia Law

The Supreme Court affirmed the judgment of the superior court dismissing Plaintiff's complaint against Defendants - Brown University and two of its officials - seeking damages and equitable relief arising out of Defendants' response to Plaintiff's sexual assault allegations, holding that the trial court did not err.Plaintiff brought his suit pursuant to the Rhode Island Civil Rights Act, chapter 112 of title 42 of the general laws (RICRA) and article 1, section 2 of the Rhode Island Constitution. The hearing justice granted Defendants' motion to dismiss for failure to state a claim, concluding that issue preclusion foreclosed the claims under RICRA based on a previous decision of the federal courts and that article 1, section 2 did not grant Plaintiff a private right of action. The Supreme Court affirmed, holding that the hearing justice did not err in dismissing Plaintiff's complaint. View "Doe v. Brown University" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of five counts related to conduct stemming from a drive-by shooting, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) there was no need to reach the merits of Defendant's belatedly raised double jeopardy contention; (2) the trial justice did not err in denying Defendant's motion to suppress an eyewitness identification; (3) the trial justice did not err by summarily denying Defendant's motion to recuse; (4) Defendant was not denied his constitutional right to self-representation; and (5) Defendant's remaining arguments were not properly preserved for appellate review. View "State v. Segrain" on Justia Law

The Supreme Court vacated the judgment of the family court convicting Defendant of cruelty to or neglect of a child and sentencing her to a one-year suspended term of imprisonment, with probation, holding that a new trial was required.On appeal, Defendant argued that the trial justice erred by proceeding with a bench trial without obtaining a knowing, intelligent, and voluntary waiver of Defendant's right to a jury trial and erred in finding habitual neglect in this case. The Supreme Court vacated the judgment below, holding that because there was nothing in the record indicating that the trial justice was assured by Defendant that her waiver of a jury trial was made intelligently and with full knowledge of the consequences of her waiver, the case must be remanded for a new trial. View "State v. Michaud" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of second-degree murder, receiving stolen goods, conspiracy, operating a vehicle on a suspended license, and carrying a knife greater than three inches in length, holding that there was no error.Specifically, the Supreme Court held (1) the trial justice did not err in denying Defendant's motion to suppress the fruits of his third interrogation; (2) the trial justice did not err by declining to redact certain prejudicial statements Defendant made while he was alone in the interrogation room; (3) Defendant's argument that his detention was extensive and that he was denied prescription medication during detention was waived; and (4) Defendant's argument that the trial justice abused his discretion by failing to suppress a witness's out-of-court identification was also waived. View "State v. Baribault" on Justia Law

The Supreme Court affirmed the judgment of conviction and commitment entered in the superior court reflecting the fact that Defendant was found guilty of second-degree murder, holding that the trial justice did not err when she denied Defendant's motion to suppress.Before trial, Defendant filed a motion to videos located on a digital camera, arguing that the detectives who seized the camera improperly expended the scope of the judicially-approved warrant. The trial justice denied the motion. After a jury trial, Defendant was found guilty of second-degree murder and sentenced to life imprisonment. The Supreme Court affirmed, holding that the trial justice did not clearly err in denying the motion to suppress because, in seizing the camera, the police did not exceed the scope of the warrant. View "State v. Depina" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of eighteen counts of financial fraud crimes and sentencing him to a total of seven years to serve in prison, with the balance of the eighteen concurrent sentences suspended with probation, holding that the trial justice did not err or abuse her discretion.Specifically, the Supreme Court held (1) the trial justice did not abuse her discretion in admitting evidence related to Defendant's character; (2) the trial justice did not err by permitted a Rhode Island State Police detective to provide expert opinion testimony as a lay witness; (3) the trial justice was not clearly wrong in allowing a waiver of the attorney-client privilege; (4) the trial justice did not err when she denied Defendant’s motion to suppress evidence he claimed was illegally obtained by state action; (5) the trial justice did not err by denying Defendant's motion for a new trial; and (6) Defendant waived his remaining allegations of error. View "State v. Doyle" on Justia Law

The Supreme Court vacated the judgment of the superior court dismissing Plaintiffs' petition alleging that the City of Providence violated the terms of two superior court consent judgments entered in 2004 and seeking to enforce those judgments and to hold the City in contempt, holding that the City violated separation-of-powers principles.Plaintiffs, a retired firefighter and two retired police officers, filed a petition to enforce the 2004 consent judgments and hold the City in contempt of those judgments. The trial justice granted summary judgment for the City, finding that a pension ordinance passed in 2012 modified Plaintiffs' rights under the consent judgments. Plaintiffs appealed, arguing that a consent judgment cannot be overruled or otherwise modified by city ordinance. The City countered that the court would have violated separation of powers principles by finding it in contempt because courts cannot restrain municipal bodies from exercising their legislative powers. The Supreme Court vacated the judgment, holding (1) by enacting the pension ordinance, the City attempted to alter a superior court decision entered in the form of the consent judgment and thereby infringed on the exercise of judicial power; and (2) therefore, to the extent that the pension ordinance purported to nullify the consent judgment, it violated separation-of-powers principles embodied in the state constitution. View "Quattrucci v. Lombardi" on Justia Law