In re E.G.S

CourtSupreme Court of Rhode Island
DecidedJune 1, 2026
Docket2024-0023-Appeal. and 2024-0024-Appeal.
StatusPublished

This text of In re E.G.S (In re E.G.S) is published on Counsel Stack Legal Research, covering Supreme Court of Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re E.G.S, (R.I. 2026).

Opinion

Supreme Court

No. 2024-23-Appeal. (NJ 22-4866) No. 2024-24-Appeal. (NJ 23-288)

In re E.G.S. :

NOTICE: This opinion is subject to formal revision before publication in the Rhode Island Reporter. Readers are requested to notify the Opinion Analyst, Supreme Court of Rhode Island, 250 Benefit Street, Providence, Rhode Island 02903, at Telephone (401) 222-3258 or Email opinionanalyst@courts.ri.gov, of any typographical or other formal errors in order that corrections may be made before the opinion is published. Supreme Court

No. 2024-23-Appeal. (NJ 22-4866) No. 2024-24-Appeal. (NJ 23-288)

Present: Suttell, C.J., Robinson, and Long, JJ.

OPINION

Chief Justice Suttell, for the Court. In these consolidated matters, the

juvenile respondent, E.G.S., appeals from two Family Court orders finding him to

be delinquent on two counts of first-degree child molestation in violation of G.L.

1956 § 11-37-8.1. The trial justice imposed on each count a suspended sentence to

the Rhode Island Training School for Youth until the respondent’s nineteenth

birthday, with probation. Additionally, he was ordered to register as a sex offender

for a period of fifteen years. On appeal, the respondent argues that the Family Court

justice erred (1) in finding him competent to stand trial and (2) in ordering him to

register as a sex offender for fifteen years. For the reasons set forth herein, we affirm

the orders of the Family Court.

-1- I

Facts and Travel

Two delinquency petitions were filed in Newport County Family Court

asserting that respondent had committed first-degree child molestation in violation

of § 11-37-8.1.

Competency Hearing

Before the trial commenced, a hearing was held over two days before the trial

justice, regarding respondent’s competency to stand trial. The respondent called two

witnesses at that hearing. The respondent first called Miguel Nuez, Ph.D., “a

postdoctoral fellow at the Adolescent Forensic and Addiction Psychology program

at the Upper Medical School of Brown University” who was in placement “at [the]

Rhode Island Family Court in the mental health clinic.” Doctor Nuñez was qualified

as an expert in the field of forensic psychology and forensic mental health. The

respondent then called Kathleen Kemp, Ph.D., the director of the Family Court

Mental Health Clinic, where she “conduct[s] forensic mental health evaluations” and

“provide[s] supervision * * * for the psychology intern and postdoctoral fellow.”

Doctor Kemp was qualified as an expert in the area of forensic psychology and

juvenile competency. A thirteen-page competency evaluation report (the report)

drafted by Dr. Nuñez and Dr. Kemp was admitted into evidence. The report

-2- described respondent’s history, mental status, and the doctors’ observations, as well

as the screening measure used in the evaluation.

In May 2023, Dr. Nuñez met with respondent twice, which he testified is

typical when conducting evaluations for competency. He explained that the first

meeting is to “gauge their understanding and appreciation, decision-making, [and]

ability to assist counsel * * *.” If the juvenile “show[s] limited knowledge in any

of these domains, [the interviewer] provide[s] them with teaching” in an attempt to

“fill in their gap of knowledge.” He then explained that the primary purpose of the

second meeting is to “gauge whether that information was learned and retained and

can be recalled.”

Doctor Nuñez also testified that, as part of initial interviews, practitioners

“gather background information from the youth * * * [which] can include things like

family history, the developmental history, mental health history, medical history,

educational history, sex or social history.” He stated that they “also conduct a mental

health status examination, including an evaluation of the mental health symptoms at

the time of the interview” and then “do the competency evaluation questions,” which

are utilized “with the juvenile during the competency interview * * *.” Doctor

Nuñez testified that he reviewed case documents—which included a risk assessment

conducted by social worker Robert Grant—and school records. He also indicated

-3- that additional records from the hospital were requested but had not been received

before he wrote the report.

Doctor Kemp testified that, when assessing competency, practitioners look at

the individual’s (1) “factual understanding,” (2) “rational understanding or

appreciation,” (3) “ability to assist counsel,” and (4) “decision-making abilities.”

According to the report, Dr. Nuñez and Dr. Kemp were of the opinion that

respondent “did not sufficiently have initial, or showed improvements in factual

understanding, rational appreciation, or adequate decision-making abilities.”

Specifically, Dr. Nuñez testified that respondent had “limited knowledge” in “his

understanding of sex offender registration,” “the role of the prosecutor[,]” and

“limited understanding of plea bargains.” He stated that respondent’s understanding

of sex offender registration was “that it could limit his ability to work at certain

places,” and he added that respondent initially said the prosecutor “would be likely

to be on his side,” but then later said “the prosecutor would be [on] either side.”

Although Dr. Nuñez provided teaching on the sex offender registration, respondent

was not “able to retain that information.” He also educated respondent on the role

of the prosecutor, which he confirmed “did not assist [respondent’s] understanding

* * *.” Doctor Nuñez stated that, after being taught what a plea deal was, respondent

stated his belief that the court “wanted to find him guilty” and that “he would have

to plead guilty in order to stay here.”

-4- On cross-examination, Dr. Nuñez agreed that he was unaware of any prior

mental health diagnoses for respondent and that he was unaware of any prior

psychiatric hospitalizations, mental health treatment, or self-harming behavior. He

further stated that, although respondent understood some repercussions of the

process, it was not “sufficient” for him to be deemed competent, adding that

respondent had an incomplete understanding of plea bargains and the role of the

prosecutor. He acknowledged that adjudicative competence did not require perfect

knowledge; however, he denied that respondent had a capacity to learn and

understand the proceedings and apply them to his case.

Competency Decision

The trial justice heard arguments from the parties on September 13, 2023, and

rendered a bench decision on October 11, 2023, finding that respondent had not met

his burden of proving “by a preponderance of the evidence that he is not competent

to stand trial pursuant to [G.L. 1956 §] 40.1-5.3-3.”

The trial justice began her decision by reviewing the procedural history of the

case and the testimony of Dr. Nuñez and Dr. Kemp. She stated that she had reviewed

the petitions, the report, and the standard for competency to stand trial as provided

in § 40.1-5.3-3, stating that “[a] person is mentally competent to stand trial if he or

she is able to understand the character and consequences of the proceedings against

him or her and is able to properly assist in his or her defense.” She found that “the

-5- testimony given and the reports submitted” did not “show by a preponderance of the

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Related

In Re Tavares
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State v. Verdone
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In re B.H.
194 A.3d 260 (Supreme Court of Rhode Island, 2018)
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