Justia Constitutional Law Opinion Summaries

The Providence Journal Company and Amanda Milkovits (collectively, the Journal) requested records from the Rhode Island State Police concerning an investigation of an underage drinking incident at property owned by the then-Governor Lincoln Chafee. The Rhode Island Department of Public Safety Department denied the Journal’s records request. Thereafter, the Journal filed a complaint against the Department, the State Police, and the Commissioner of the Department (collectively, Defendants) alleging violations of Rhode Island’s Access to Public Records Act (APRA). The superior court granted summary judgment to Defendants, concluding that the requested documents were not subject to public disclosure pursuant to the APRA. The Supreme Court affirmed, holding that the records request was properly denied pursuant to the APRA. View "Providence Journal Co. v. R.I. Dep’t of Pub. Safety" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and related crimes. Defendant appealed, arguing that the trial justice erred in (1) failing to grant his motion to suppress evidence that was obtained as a result of his warrantless arrest in his home, and (2) failing to remove two allegedly biased jurors from the jury or, in the alternative, to grant a mistrial. The Supreme Court vacated the judgment of the superior court and remanded for a new trial, holding (1) the trial justice erred in denying Defendant’s motion to suppress, as the warrantless entry into Defendant’s home was not consented to freely and voluntarily, and the State failed to establish the existence of exigent circumstances to justify the entry into the home; and (2) the error in this case was not harmless. Remanded for a new trial. View "State v. Gonzalez" on Justia Law

The Rhode Island Department of Transportation (RIDOT) condemned a parcel of real property owned by Richard Deeble and his wife for highway purposes. The Deebles subsequently died. RIDOT utilized only a portion of the condemned property in furtherance of the relocation of an interstate. Plaintiff, the Estate of Richard Deeble, sought declaratory and injunctive relief against RIDOT, asserting that should RIDOT seek to sell or lease the condemned property, the Estate was entitled to a right of first refusal to repurchase or lease the land in accordance with article 6, section 19 of the Rhode Island Constitution. The superior court justice concluded that the provisions of article 6, section 19 did not pass to the Estate. The Supreme Court affirmed, holding that the rights guaranteed by article 6, section 19 terminate upon the death of the original condemnee. View "Estate of Richard J. Deeble v. Dep’t of Transp." on Justia Law

After a jury trial, Appellant was convicted of conspiracy to commit assault with a dangerous weapon and assault with a dangerous weapon. Appellant was also charged with first-degree murder, but the jury was unable to reach a verdict on that charge. After a second jury trial, Appellant was convicted of one count of first-degree murder. Appellant later filed an application for postconviction relief, arguing that his second trial was not fair because the justice who presided over that trial had previously represented Appellant in family court when Appellant was a minor. Appellant also alleged that his counsel at the second murder trial was ineffective. After a hearing, the hearing justice denied postconviction relief. The Supreme Court affirmed, holding (1) the hearing justice did not err in denying postconviction relief on the grounds that the trial justice at Appellant’s second murder trial should have recused; and (2) Appellant’s counsel did not provide ineffective assistance at Appellant’s second murder trial. View "Perry v. State" on Justia Law

After a jury trial, Defendant was convicted of one count of felony domestic assault, two counts of assault with a dangerous weapon, and one count of simple domestic assault after previously having been convicted twice of domestic assault. The Supreme Court affirmed. Defendant later filed an application for postconviction relief, alleging that his trial counsel was ineffective because he stipulated to the fact that Defendant had two prior convictions for domestic violence in the presence of the jury. The Supreme Court affirmed, holding that trial counsel’s performance was not deficient, and even if Defendant were able to establish that his trial counsel was ineffective, Defendant’s right to a fair trial was not prejudiced by his trial counsel’s conduct. View "Snell v. State" on Justia Law

A criminal complaint was filed against Defendant charging him with burglary. After a combined bail and violation hearing, a hearing justice found that Defendant failed to be of good behavior and that Defendant violated the terms of his violation. Defendant appealed, arguing, inter alia, that evidence obtained from the search of a vehicle should have been suppressed because it was obtained from an illegal search and seizure. The Supreme Court affirmed, holding (1) Defendant lacked standing to contest the legality of the search of the vehicle; (2) even assuming the police illegally obtained the evidence, the exclusionary rule did not apply at Defendant’s probation revocation hearing; and (3) the hearing justice did not act arbitrarily or capriciously in finding that Defendant violated his probation. View "State v. Ditren" on Justia Law

After a jury trial, Defendant was convicted of two counts of assault with a dangerous weapon and one count of simple assault. On appeal, Defendant argued, among other things, that the prosecutor improperly vouched for the credibility of two witnesses during her closing argument. The Supreme Court affirmed the convictions, holding (1) the trial justice did not abuse his discretion by allowing the state to impeach Defendant’s credibility with his fourteen prior criminal convictions; and (2) although a portion of the prosecutor’s closing argument was akin to vouching, the trial justice did not err by refusing to pass the case. View "State v. Whitfield" on Justia Law

After a jury trial, Defendant was found guilty of two counts of second-degree child molestation sexual assault. The Supreme Court affirmed the superior court’s judgment of conviction and its denial of Defendant’s motion for a new trial, holding (1) the trial justice did not abuse his discretion in denying Defendant’s motion to pass the case after the prosecutor engaged in an improper line of questioning to a witness, as any prejudice which may have resulted was cured by the trial justice’s instruction to the jury; and (2) the trial justice did not misconceive or overlook material testimony and did not otherwise commit clear error in denying Defendant’s motion for a new trial. View "State v. Hie" on Justia Law

In 1990, Applicant was convicted of one count of first-degree sexual assault. In 2001, Applicant filed a pro se application for postconviction relief, alleging ineffective assistance of counsel and trial error. In 2005, the hearing justice denied the application. The Supreme Court affirmed, holding that the hearing justice properly did not commit clear error or misconceive material evidence in rendering his decision, as (1) Applicant’s claims relating to alleged errors committed by the trial justice were barred by the doctrine of res judicata; and (2) Applicant failed to show to his trial counsel’s representation fell below an objective standard of reasonableness. View "Lamoureux v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree child molestation and one count of second-degree child molestation. The Supreme Court affirmed the convictions on direct appeal. Appellant subsequently filed an application for postconviction relief, arguing that his trial counsel provided ineffective assistance. The trial justice denied the application, concluding that Appellant failed to establish that his counsel’s performance was deficient. The Supreme Court affirmed, holding that the trial justice did not err in finding that trial counsel performed at a high level and in thus denying Appellant’s application for postconviction relief. View "Merida v. State" on Justia Law