Kyle Campbell v. State of Rhode Island
56 A.3d 448
| R.I. | 2012Background
- Campbell was convicted of first-degree murder in 1995 as a juvenile.
- On March 22, 2004, Campbell filed a pro se postconviction-relief application alleging six errors.
- The State moved to dismiss, triggering dismissal of five allegations based on res judicata and other grounds.
- The trial court dismissed five allegations on April 1, 2005 and appointed an independent evaluator for one remaining claim.
- Campbell was not provided with court-appointed counsel as § 10-9.1-5 requires for indigent applicants, and he remained unrepresented during the proceedings.
- The Supreme Court vacated the judgment and remanded for appointment of counsel under § 10-9.1-5; it also addressed the Family Court waivers of jurisdiction as a matter to be resolved after counsel is appointed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether indigent postconviction relief applicants are entitled to counsel before dismissal | Campbell argues § 10-9.1-5 requires counsel prior to dismissal | State contends summary dismissal permissible under § 10-9.1-6(b) | Yes, remanded to appoint counsel before dismissal |
| Whether five meritless claims were properly summary dismissed without counsel | Without appointed counsel, Campbell lacked meaningful opportunity to reply | Claims were barred by res judicata or lacked merit | Error; remand for counsel and proper procedure |
| Whether the appointment of an independent, non-representing attorney violated § 10-9.1-5 | Shatney framework does not permit an independent evaluator; Campbell is entitled to counsel | Independent evaluator permissible under court procedure | Independent evaluator improper; appoint counsel to represent applicant; remand for guidance per statute |
| Whether the Superior Court lacked jurisdiction to hear Family Court waiver claims | Family Court waiver claims arise from juvenile proceedings; should be in Superior Court | Waiver issues are outside Superior Court's reach | Remand to address with counsel; no final jurisdictional ruling |
Key Cases Cited
- Shatney v. State, 755 A.2d 130 (R.I. 2000) (appointing process and no-merit memorandum; counsel withdrawal rules under § 10-9.1-5; need for meaningful opportunity to be heard)
- Harris v. State, 553 A.2d 433 (Pa. Super. Ct. 1989) (mandatory appointment is essential before dismissing pro se postconviction relief)
- O'Neil v. State, 814 A.2d 366 (R.I. 2002) (error in denying relief without appointed counsel in first application)
- Louro v. State, 740 A.2d 343 (R.I. 1999) (limits appointment of counsel in successive applications)
- Taylor v. Wall, 821 A.2d 685 (R.I. 2003) (res judicata governs postconviction claims; summary dismissal where appropriate)
- Sifuentes v. State, 43 A.3d 49 (R.I. 2012) (clarifies summary dismissal procedure in § 10-9.1-6(b))
- Sosa v. State, 949 A.2d 1014 (R.I. 2008) (standard for postconviction relief review and continuance of proceedings)
- Ramirez v. State, 933 A.2d 1110 (R.I. 2007) (distinguishes cases where meaningful hearing is required notwithstanding later dispositions)