Joao Neves v. State of Rhode Island Keith Nunes v. State of Rhode Island Pablo Ortega v. State of Rhode Island Mario Monteiro v. State of Rhode Island

CourtSupreme Court of Rhode Island
DecidedJuly 2, 2024
Docket2022-0092-M.P. and 2022-0093-M.P. and 2022-0094-M.P. and 2023-0167-M.P.
StatusPublished

This text of Joao Neves v. State of Rhode Island Keith Nunes v. State of Rhode Island Pablo Ortega v. State of Rhode Island Mario Monteiro v. State of Rhode Island (Joao Neves v. State of Rhode Island Keith Nunes v. State of Rhode Island Pablo Ortega v. State of Rhode Island Mario Monteiro v. State of Rhode Island) 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
Joao Neves v. State of Rhode Island Keith Nunes v. State of Rhode Island Pablo Ortega v. State of Rhode Island Mario Monteiro v. State of Rhode Island, (R.I. 2024).

Opinion

Supreme Court

(Dissent begins on Page 50)

Joao Neves : No. 2022-92-M.P. (PM 22-259) v. :

State of Rhode Island. :

Keith Nunes : No. 2022-93-M.P. (PM 22-901) v. :

Pablo Ortega : No. 2022-94-M.P. (PM 22-260) v. :

Mario Monteiro : No. 2023-167-M.P. (PM 23-921) v. :

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

Present: Suttell, C.J., Goldberg, Robinson, Lynch Prata, and Long, JJ.

OPINION

Justice Goldberg, for the Court. The United States Supreme Court has held

that it is unconstitutional to impose upon individuals who were under eighteen years

old at the time of their crimes: sentences of death, life imprisonment without parole

-1- for a nonhomicide offense, or mandatory life imprisonment without parole. 1 In

arriving at these decisions, the Supreme Court “relied on three significant gaps

between juveniles and adults”; namely, individuals under eighteen years of age

possess a “lack of maturity and an underdeveloped sense of responsibility,” which

often leads “to recklessness, impulsivity, and heedless risk-taking”; younger persons

“are more vulnerable * * * to negative influences and outside pressures,” including

peer pressure, “have limited ‘control over their own environment’ and lack the

ability to extricate themselves from horrific, crime-producing settings”; and a

juvenile’s “character is not as ‘well formed’ as an adult’s[,] his traits are ‘less fixed’

and his actions less likely to be ‘evidence of irretrievable depravity.’” Miller v.

Alabama, 567 U.S. 460, 471 (2012) (brackets omitted) (quoting Roper v. Simmons,

543 U.S. 551, 569-70 (2005)). As explained, “[t]hese salient characteristics mean

that ‘it is difficult even for expert psychologists to differentiate between the juvenile

offender whose crime reflects unfortunate yet transient immaturity, and the rare

1 See Miller v. Alabama, 567 U.S. 460, 465 (2012) (“We therefore hold that mandatory life without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment’s prohibition on ‘cruel and unusual punishments.’”); Graham v. Florida, 560 U.S. 48, 82 (2010) (“The Constitution prohibits the imposition of a life without parole sentence on a juvenile offender who did not commit homicide.”); Roper v. Simmons, 543 U.S. 551, 578 (2005) (“The Eighth and Fourteenth Amendments forbid imposition of the death penalty on offenders who were under the age of 18 when their crimes were committed.”).

-2- juvenile offender whose crime reflects irreparable corruption.’” Graham v. Florida,

560 U.S. 48, 68 (2010) (brackets omitted) (quoting Roper, 543 U.S. at 573).

Here, we are confronted with a different dynamic as set forth in G.L. 1956

§ 13-8-13(e) (Subsection (e) or the amendment), but it embodies many of the same

principles discussed in Miller, Graham, and Roper—“the distinctive attributes of

youth diminish the penological justifications for imposing the harshest sentences on

juvenile offenders, even when they commit terrible crimes.” Miller, 567 U.S. at 472.

Enacted in 2021, notably as part of the FY 2022 state budget, Subsection (e) states

in full:

“Any person sentenced for any offense committed prior to his or her twenty-second birthday, other than a person serving life without parole, shall be eligible for parole review and a parole permit may be issued after the person has served no fewer than twenty (20) years’ imprisonment unless the person is entitled to earlier parole eligibility pursuant to any other provisions of law. This subsection shall be given prospective and retroactive effect for all offenses occurring on or after January 1, 1991.” (Emphasis added.)

The parties—the State of Rhode Island (petitioner or state) and Joao Neves,

Keith Nunes, Pablo Ortega, and Mario Monteiro (collectively, respondents)—offer

conflicting interpretations of Subsection (e). The state contends that because

Subsection (e) employs the phrase “any offense”—in the singular—Subsection (e)

is intended to reduce parole eligibility for a single sentence and that qualified

offenders serving multiple sentences, such as respondents, are not eligible for a -3- reduction in parole eligibility pursuant to the amendment’s terms. (Emphasis added.)

The respondents counter that Subsection (e) applies to “any offense,” and thus

submit that based upon the meaning and breadth of the term “any,” the amendment

requires aggregating (or combining) multiple sentences for qualified offenders,

including consecutive sentences. (Emphasis added.)

For the reasons discussed below, we hold that Subsection (e) mandates the

aggregation of a qualified offender’s sentences, including consecutive sentences,

and the Court further concludes that Subsection (e), as interpreted, does not violate

the separation-of-powers doctrine. However, the Court declares that although

Subsection (e) applies to respondents, the trial justice erred when he ordered each

respondent immediately paroled to the community. We explain herein.2

Facts and Travel

We first consider the aggregation of prison sentences for parole eligibility.

For those incarcerated and serving multiple terms, whether or not the sentences are

aggregated can mean the difference between serving a sentence in prison and serving

a sentence outside the prison walls, such as on parole. In this context, aggregation

2 We express our gratitude for the amici curiae briefs submitted by the Rhode Island Department of Corrections; the Rhode Island Parole Board; the Rhode Island Public Defender; the Roger Williams University School of Law Prisoners’ Rights Clinic; the Juvenile Law Center, the Sentencing Project, the Gault Center, the National Association of Criminal Defense Lawyers, and the Prison Policy Initiative; the Campaign for the Fair Sentencing of Youth, Human Rights for Kids, and Aliza Hochman Bloom; and the Center for Law, Brain and Behavior. -4- means combining the sum total of all pending sentences. To illustrate, an offender

receiving three consecutive ten-year terms would be sentenced to imprisonment for

thirty years, but in accordance with § 13-8-10(a), the offender is eligible for parole

after serving “a term equal to one-third (⅓) of the aggregate time which he or she

shall be liable to serve under his or her several sentences,” in other words, ten years.

The parties agree that the prerequisites to Subsection (e) are satisfied: Each

respondent committed his crimes after January 1, 1991, the crimes were committed

before each respondent was twenty-two years old, none of the respondents were

sentenced to life imprisonment without parole, and each respondent has served at

least twenty years at the Adult Correctional Institutions. They also agree that three

respondents (Neves, Ortega, and Nunes) have been sentenced to life imprisonment,

and a specified term (a number of years) of incarceration, to be served consecutively

to the life sentence; and that Monteiro is serving two consecutive life sentences. The

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Anderson v. Corall
263 U.S. 193 (Supreme Court, 1923)
Hewitt v. Helms
459 U.S. 460 (Supreme Court, 1983)
Whitman v. American Trucking Assns., Inc.
531 U.S. 457 (Supreme Court, 2001)
Nixon v. Missouri Municipal League
541 U.S. 125 (Supreme Court, 2004)
Roper v. Simmons
543 U.S. 551 (Supreme Court, 2005)
Small v. United States
544 U.S. 385 (Supreme Court, 2005)
Hope Billings McCulloch v. James Robert McCulloch
69 A.3d 810 (Supreme Court of Rhode Island, 2013)
State v. Adrian Hazard
68 A.3d 479 (Supreme Court of Rhode Island, 2013)
State v. James Briggs. State v. Anna M. Matthias (Mathias)
58 A.3d 164 (Supreme Court of Rhode Island, 2013)
State v. Eileen Morrice
58 A.3d 156 (Supreme Court of Rhode Island, 2013)
Elizabeth Boyer v. Chief Judge Haiganush Bedrosian
57 A.3d 259 (Supreme Court of Rhode Island, 2012)
State v. Bryant
670 A.2d 776 (Supreme Court of Rhode Island, 1996)
State v. Mann
382 A.2d 1319 (Supreme Court of Rhode Island, 1978)
Long v. Dell, Inc.
984 A.2d 1074 (Supreme Court of Rhode Island, 2009)
State v. Caprio
477 A.2d 67 (Supreme Court of Rhode Island, 1984)
State v. Ouimette
367 A.2d 704 (Supreme Court of Rhode Island, 1976)
State v. Mariano
648 A.2d 803 (Supreme Court of Rhode Island, 1994)
State v. Clark
974 A.2d 558 (Supreme Court of Rhode Island, 2009)

Cite This Page — Counsel Stack

Bluebook (online)
Joao Neves v. State of Rhode Island Keith Nunes v. State of Rhode Island Pablo Ortega v. State of Rhode Island Mario Monteiro v. State of Rhode Island, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joao-neves-v-state-of-rhode-island-keith-nunes-v-state-of-rhode-island-ri-2024.