Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed the order of the superior court dismissing Plaintiff’s complaint for declaratory relief asserting that he had a right to access to records in the possession of the Rhode Island Department of Elementary and Secondary Education (RIDE) pursuant to the Access to Public Records Act (APRA). The motion justice found that the requested documents were not public records subject to disclosure under APRA. The Supreme Court agreed, holding that the records requested by Plaintiff were not public records for the purposes of APRA, and therefore, the motion justice properly disposed of Plaintiff’s complaint on RIDE’s motion to dismiss. View "Pontarelli v. R.I. Department of Elementary & Secondary Education" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting the City of Providence’s motion for summary judgment in this lawsuit filed by Lehigh Cement Co. seeking to recover approximately $500,000 in real estate taxes billed and collected by the city from 2006 to 2009. The court held (1) the hearing justice did not err in granting summary judgment on Lehigh’s claim under R.I. Gen. Laws 44-5-23, as the statute does not provide relief to a taxpayer; (2) summary judgment on Lehigh’s claim under the fair distribution clause of the Rhode Island Constitution was appropriate; and (3) the hearing justice did not err in granting summary judgment on Lehigh’s claim under R.I. Gen. Laws 44-5-27. View "Lehigh Cement Co. v. Quinn" on Justia Law

The Supreme Court vacated the judgments of conviction entered in the superior court following a jury trial convicting Defendant of three counts of assault with a dangerous weapon and one count of carrying a pistol without a license. The Supreme Court held (1) the superior court justice erred in denying Defendant’s motion to suppress evidence seized by police during a warrantless search of Defendant’s home because the state failed to overcome the presumption of unreasonableness that accompanies every warrantless entry into a home; and (2) the admission of the unlawfully seized evidence was not harmless beyond a reasonable doubt. View "State v. Terzian" on Justia Law

Defendant was charged via a criminal information with breaking and entering a dwelling. After a trial, the trial justice granted Defendant’s motion to pass the case based on based on a comment made by the prosecutor during closing argument. Thereafter, Defendant filed a motion to dismiss the information on grounds of double jeopardy. The trial justice denied Defendant’s motion to dismiss, ruling that the State’s actions were not intended to goad Defendant into seeking a mistrial. The Supreme Court affirmed, holding that the trial justice did not err in determining that the prosecutor did not intentionally goad Defendant into moving for a mistrial. View "State v. Corleto" on Justia Law

Defendant pleaded nolo contendere to assault in a dwelling house with intent to murder while armed with a dangerous weapon and carrying a pistol on or about his person without a license. While Defendant was on parole, he was arrested and charged with domestic assault and failure to relinquish a telephone. Also while on parole Defendant was charged with breaking and entering. After a hearing, Defendant admitted that he violated the terms and conditions of his probation. Defendant later filed an application for postconviction relief alleging that he was denied the effective assistance of counsel at the probation violation hearing and that he did not knowingly, intelligently, and voluntarily admit a violation of probation. A hearing justice denied Defendant’s application for postconviction relief. The Supreme Court affirmed, holding (1) any alleged deficient performance by Defendant’s attorney was not so prejudicial as to deprive Defendant to a fair trial; and (2) Defendant’s admission was made knowingly, intelligently, and voluntarily. View "Gomes v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction on five counts of first-degree child molestation rendered after a jury trial. After denying Defendant’s motion for a new trial, the trial justice sentenced Defendant to five concurrent life sentences. The Supreme Court held (1) in dealing with Defendant’s motion for a new trial, the trial justice did not commit clear error or overlook or misconceive material and relevant evidence relating to a critical issue in the case; and (2) Defendant’s “constitutional right to present a full and fair defense” was not denied when the trial justice minimally limited Defendant’s cross-examination of two witnesses. View "State v. Ogoffa" on Justia Law

Defendant pled nolo contendere to one count of second-degree sexual assault and one count of intimidation of a witness in a criminal proceeding. Defendant filed an application for postconviction relief alleging that his sentence and conviction were unconstitutional due to the ineffective assistance of counsel. A hearing justice denied postconviction relief, concluding that Defendant made a knowing and intelligent plea at the time of his plea. The Supreme Court affirmed, holding (1) Defendant failed to provide the evidence required to support a claim of ineffective assistance of counsel; and (2) the justice who conducted the postconviction relief hearing did not overlook or misconceive material evidence in arriving at her findings. View "Njie v. State" on Justia Law

Defendant was convicted of several criminal counts, including burglary and conspiracy to commit burglary. The aggregate sentences for all of Defendant’s convictions totaled thirty-five years. Defendant subsequently moved to reduce his sentence pursuant to Rule 35 of the Superior Court Rules of Criminal Procedure, arguing, inter alia, that he accepted responsibility for his actions and that his sentence violated the Eighth Amendment. The hearing justice denied Defendant’s motion to reduce sentence. On appeal, Defendant argued that his violated the Sixth Amendment and the Eighth Amendment. The Supreme Court affirmed, holding (1) the hearing justice was within his discretion to confirm Defendant’s punishment; (2) Defendant’s constitutional challenges were not cognizable in the context of a motion to correct an illegal sentence under Rule 35; and (3) even if Defendant could raise constitutional challenges under Rule 35, his arguments lacked merit. View "State v. Ciresi" on Justia Law

In 1994, Applicant entered a plea of nolo contendere to the offense of maintaining a narcotics nuisance. In 2012, Applicant filed a pro se application seeking to vacate his nolo contendere plea. In his application Applicant argued that his plea was not knowing, intelligent, and voluntary and that his counsel provided ineffective assistance. The hearing justice entered judgment for the State and dismissed the application. The Supreme Court affirmed, holding (1) the trial justice did not err in finding that Applicant understood the nature and consequences of his plea; (2) the trial justice properly dismissed Applicant’s claims of ineffective assistance of counsel; and (3) the efforts of postconviction counsel were adequate. View "Reyes v. State" on Justia Law

This case involved a shooting that occurred in the City of Woonsocket, which left Ikey Wilson with severe injury to his stomach and required the amputation of his right leg. Defendant Christian Rosado appealed his conviction on two separate counts of assault with a dangerous weapon (firearm). Defendant maintained that the hearing justice erred in denying his motion for a mistrial based on what he perceived to have been the state’s discovery violation. Finding no reversible error, the Supreme Court affirmed. View "Rhode Island v. Rosado" on Justia Law