Elizabeth Boyer v. Chief Judge Haiganush Bedrosian
57 A.3d 259
| R.I. | 2012Background
- Truancy Court Diversion Calendar Program started in 1999 to address truancy by holding court sessions at schools.
- In 2010, plaintiffs sued the Family Court chief judge, magistrates, administrators, and several municipalities alleging due process violations.
- Administrative Order 2010-2 reformed procedures: intake, notice, trial rights, interpreters, recording, and potential referral to juvenile calendar.
- The Superior Court denied motions to dismiss; certiorari petitions were granted; the Rhode Island Supreme Court reviewed jurisdiction, standing, mootness, comity, and immunities.
- The Supreme Court ultimately held the case moot, quashing the Superior Court order and remanding to enter a final judgment dismissing as moot.
- The decision discusses mootness theory, administrative order effects, and potential mootness exceptions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the claims are moot after 2010-2 | Mootness not raised below; order does not address all challenges | Administrative order divests ongoing controversy | Moot; claims dismissed as moot |
| Whether mootness exception for extreme public importance applies | Issues are of extreme public importance and capable of repetition | No appropriate repetition or evasion of review; order binds current practice | No exception applies; case remains moot |
| Whether comity/abstention precluded Superior Court review | Superior Court should rule; comity not applicable | Family Court has concurrent/overlapping jurisdiction | Not reached on merits due to mootness; no substantive ruling on comity provided |
| Whether standing/continuing stake existed to keep case live | Some plaintiffs had ongoing, threatened injury; proposed class action | Many plaintiffs were dismissed or settled; no imminent injury remained | mootness requires dismissal; no live controversy |
Key Cases Cited
- Moreau v. Flanders, 15 A.3d 565 (R.I. 2011) (mootness and due process notice standards applied)
- In re Leon, 122 R.I. 548 (R.I. 1980) (intake investigation purpose to shield from arbitrary action)
- In re Three Minor Children, 110 R.I. 11 (R.I. 1972) (preliminary investigation and jurisdictional concerns in juvenile matters)
- Arnold v. Lebel, 941 A.2d 813 (R.I. 2007) (ex parte communications and due process considerations in administrative actions)