Cody-Allen Zab v. Rhode Island Department of Corrections Jose R. Rivera v. State of Rhode Island Department of Corrections, by and through its Director, Patricia Coyne-Fague, in her official capacity

Syllabus

The plaintiffs, Cody-Allen Zab and Jose R. Rivera, appealed from Superior Court judgments entered in favor of the Rhode Island Department of Corrections, Director Patricia Coyne-Fague in her official capacity, and Global TelLink Corporation. Before the Supreme Court, the plaintiffs argued that the trial court erred in finding that it did not have jurisdiction to hear the plaintiffs' claims based on G.L. 1956 § 13-6-1, Rhode Island's civil death statute. The Supreme Court first addressed Zab's claim that the civil death statute violates the Supremacy Clause of the United States Constitution and concluded that the hearing justice properly dismissed Zab's federal claim on the merits. The Supreme Court recognized that, under the relevant federal statute, the DOC and the DOC Director were not \persons\ and Zab had no right of action against them. The Supreme Court then addressed plaintiffs' contentions that the civil death statute unconstitutionally divested the Superior Court of authority to hear their negligence claims. The Supreme Court concluded that the civil death statute violates article 1, section 5 of the Rhode Island Constitution because it denies plaintiffs of their fundamental right of access to the courts. The Supreme Court applied strict scrutiny and concluded that the state failed to demonstrate a compelling reason to override the right of access to the courts that is textually guaranteed by the Rhode Island Constitution. The Supreme Court ultimately determined that the entirety of the civil death statute is unconstitutional and in clear contravention of the provisions of article 1, section 5, of the Rhode Island Constitution because it deprives those persons imprisoned at the Adult Correctional Institutions for life of their right to bring civil actions in our state courts.