Price v. Wall
31 A.3d 995
R.I.2011Background
- Craig Price admitted four brutal 1989 murders as a juvenile and was committed to the Training School until age 21 for rehabilitation.
- Family Court ordered psychiatric treatment; Price repeatedly refused, citing Fifth Amendment privilege and fear of civil commitment.
- Civil contempt findings were entered against Price in 1990s for failing to comply with treatment orders.
- Criminal contempt conviction followed after a four-day trial, resulting in a 25-year sentence (10 to serve, 15 suspended with probation).
- Price appealed directly to the Rhode Island Supreme Court and later sought postconviction relief; those petitions were denied.
- The Court affirmed the Family Court’s denial of postconviction relief after review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Double jeopardy claim after civil and criminal contempt | Price argues civil and criminal contempt violate double jeopardy. | State argues previous Price decision controls; res judicata bars relitigation. | No error; res judicata bars reconsideration; double jeopardy claim rejected. |
| Ineffective assistance of appellate counsel | Appellate counsel failed to raise the double jeopardy issue. | Counsel did not perform deficiently given lack of merit. | Claim fails; no ineffective assistance. |
| Excessiveness of the sentence | Sentence was excessive under the Eighth Amendment. | Court acted within discretion; rehabilitation focus and deterrence justified. | Sentence not excessive; within trial court’s discretion. |
| Probationary term revocation and timing | Price argues probation term did not commence; revocation improper. | Good-behavior condition attaches when suspended sentence pronounced; revocation proper. | Revocation upheld; principle of good behavior attaches at pronouncement. |
Key Cases Cited
- Price v. State, 820 A.2d 956 (R.I.2003) (direct appeal upholding contempt conviction and related rulings)
- Thornley v. Mullen, 115 R.I. 505 (1975) (res judicata precludes relitigating issues from prior direct appeal)
- Kremer v. Chemical Construction Corp., 456 U.S. 461 (1982) (preclusion principles in res judicata (federal rule reference))
- Plunkett v. State, 869 A.2d 1185 (R.I.2005) (preclusion and final judgment principles in Rhode Island)