State v. Beaudoin
Annotate this CaseIn 2010, the General Assembly amended R.I. Gen. Laws 12-19-18 to provide that a sentence of imprisonment after a finding of probation violation shall be quashed and the imprisonment terminated in certain circumstances occurring after a judgment of probation violation. In 2009, Defendant pled nolo contendere to felony assault. In 2012, while on probation, Defendant was charged with second-degree sexual assault and robbery. The State filed a notice of probation violation based on the conduct giving rise to these charges. The trial justice declared Defendant to be a probation violator and ordered him to serve two years of his suspended sentence. Thereafter, Defendant was acquitted on both counts. Defendant filed a motion to terminate his imprisonment. The trial justice denied Defendant’s motion, concluding (1) application of section 12-19-18(b) required impermissible retroactive application of the 2010 amendment; and (2) even if applied prospectively, section 12-19-18(b) constituted an unconstitutional exercise of judicial power by the General Assembly. The Supreme Court vacated the judgment of the superior court, holding (1) this case entails prospective, not retroactive, application of the statute; and (2) the trial justice was without authority to decide, sua sponte, a constitutional issue that was not raised by the parties.
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