137 A.3d 717
R.I.2016Background
- Beaudoin pled nolo contendere in 2009 to felony assault; sentenced to 15 years with 5 months to serve and 175 months suspended with probation.
- The General Assembly amended § 12-19-18(b) in 2010, providing for quashing imprisonment after a probation violation under certain conditions.
- In 2012 Beaudoin was adjudicated a probation violator and two years of the suspended sentence were ordered to be served at the ACI.
- In 2013 Beaudoin was acquitted on the underlying charges after a jury trial.
- Beaudoin moved to terminate imprisonment under § 12-19-18(b); the trial justice denied the motion, reasoning retroactive application and then constitutional concerns.
- Rhode Island Supreme Court vacated the denial, held the statute applies prospectively, and remanded for proceedings; it did not decide the constitutionality of prospective application.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prospective vs retroactive application of § 12-19-18(b)? | Beaudoin argues retroactive application is required. | State contends retroactive application is necessary. | Prospective application determined. |
| Constitutionality of § 12-19-18(b) when applied prospectively? | State contends constitutional; trial judge deemed unconstitutional. | Beaudoin argues it is unconstitutional to apply prospectively. | Court did not decide constitutional issue; vacated as not necessary to resolve this case. |
| Was the trial judge's sua sponte constitutional ruling proper? | Not explicitly argued by parties; judge exceeded scope. | N/A. | Trial judge’s sua sponte constitutional ruling vacated; no opinion on constitutionality. |
Key Cases Cited
- State v. Garnetto, 75 R.I. 86 ((1949)) (distinguishable retroactivity analysis when prestatute conduct was adjudicated prior to enactment)
- State v. Desjarlais, 731 A.2d 716 ((R.I. 1999)) (retrospective vs prospective in Rhode Island retroactivity framework)
- Rhode Island Insurers’ Insolvency Fund v. Leviton Manufacturing Co., 716 A.2d 730 ((R.I. 1998)) (triggering events determine retroactivity; insolvency event controls)
- State v. Gautier, 774 A.2d 882 ((R.I. 2001)) (probation violation context; noncriminal violations not within §12-19-18(b))
- Landgraf v. USI Film Prods., 511 U.S. 244 ((U.S. 1994)) (test for retroactivity balancing changes in legal consequences)
- McAndrews v. Fleet Bank of Massachusetts, N.A., 989 F.2d 13 ((1st Cir. 1993)) (prospective application where later event triggers statute)