Thomas H. Roberts

The case involved the Blackstone Valley Chamber of Commerce's petition for certiorari challenging a Public Utilities Commission order that replaced a declining block rate structure with a flat rate for residential electric customers of Blackstone Valley Electric Company. The commission had consolidated dockets on a rate increase and prior remands, ultimately applying an across-the-board revenue allocation and altering the residential rate design. The court focused on the threshold issue of standing under G.L. 1956 § 39-5-1, which permits review only by persons aggrieved by the commission's order. It reasoned that standing requires a showing of injury in fact to the petitioner, that the chamber had not demonstrated any personal stake or adverse effect from the residential rate change (as opposed to business interests), and that no substantial public interest justified bypassing the statutory requirement.

business & regulatoryprocedure

The case involved challenges by the Rhode Island Chamber of Commerce Federation and Newport Electric Corporation to actions by the Public Utilities Commission regarding electricity rate designs for Newport. The court addressed whether the commission could modify a utility's proposed rate design and whether there was sufficient evidence for an intra-class allocation of costs among residential customers. The court held that the commission has the authority to formulate rate designs different from those submitted by the utility, based on state statutes granting it broad regulatory powers to ensure just and reasonable rates. However, it remanded the case for further proceedings because the record did not adequately support the specific residential rate design adopted. The decision emphasized the legislative intent for the commission to have implied powers necessary for effective regulation.

business & regulatoryprocedure

This case concerns a petition by Capitol Building Company for a refund of a use tax assessed by the state tax administrator on prefabricated garage components purchased from an out-of-state supplier and used in Rhode Island construction projects. The superior court certified the matter to the supreme court on an agreed statement of facts, with the taxpayer arguing that the transaction was subject to sales tax and that imposition of the use tax was improper or that an exemption under §44-18-34 applied. The court held that the use tax was validly assessed and that the petition for refund should be denied. It reasoned that the use tax provisions are complementary to the sales tax and apply unless the taxpayer demonstrates either payment of the sales tax via receipt or qualification for the exemption by showing that the gross receipts from the property's disposition would be included in its own sales tax measure, which the taxpayer failed to establish here.

taxesbusiness & regulatory

The case concerned whether evidence seized from a dwelling house pursuant to a federal search warrant could be used in Rhode Island state court prosecutions for gambling offenses, even though the warrant did not comply with additional state statutory requirements under G.L. 1956 §11-19-24 for gambling apparatus searches in dwellings. Defendants moved to suppress the evidence obtained in a joint federal-state raid, and the superior court certified the admissibility question to the supreme court. The court decided that the evidence was admissible and answered the certified question in the affirmative. It reasoned that the federal warrant satisfied the probable cause standards of the Fourth Amendment and the equivalent state constitutional provision, that the state exclusionary statute (§9-19-25) bars only evidence from constitutionally illegal searches, and that the specialized state warrant procedures do not apply to or invalidate a federal warrant.

criminal lawprocedurefederal power

This case involved a claim of false arrest after a police officer detained the plaintiff based on a description of a suspected peeping Tom, took him to the station for identification, and released him within two hours when no one identified him. The trial court ruled in favor of the defendant officer, finding the detention justified under a state statute allowing up to two hours of detention upon reasonable suspicion. On appeal, the plaintiff argued the statute was unconstitutional, but the Supreme Court affirmed the judgment, holding that the officer could rely on the presumptive validity of the statute without liability for false arrest, following precedent that protects officers enforcing statutes later found invalid.

criminal lawproceduretorts & liability

The case involved an indictment against employer Howard N. Feist, Jr. and Shepard Company for violating a Rhode Island statute (G.L. 1956 §28-14-2) by failing to pay wages to employees on a weekly basis, with penalties under §28-14-17 that included possible imprisonment. Feist moved to dismiss, arguing the law violated article I, section 11 of the state constitution by authorizing imprisonment to enforce a debt. The trial court granted the motion, but on appeal the Rhode Island Supreme Court reversed, holding that the statute is a valid penal measure. The court reasoned that the 1941 amendments to the wage-payment law—extending coverage to all employers, eliminating any share of fines for complainants, and explicitly labeling violations as misdemeanors—demonstrated a legislative intent to protect public welfare through criminal sanctions rather than to collect private debts. Because the constitution only bars continued imprisonment for debt after surrender of assets (absent fraud), the criminal penalties did not violate the provision.

criminal lawlabor & employment