In re 38 Studios Grand Jury

Syllabus

Governor Gina M. Raimondo appealed from a judgment of the Superior Court denying her petition to disclose all materials from the grand jury that investigated the state's 38 Studios bond deal because (1) it did not have the authority to disclose grand jury materials outside of the enumerated disclosures it is permitted to make under Rule 6(e) of the Superior Court Rules of Criminal Procedure (2) the Governor did not demonstrate a particularized need for the information requested and (3) policy factors did not favor disclosure. The Governor argued that the Superior Court has inherent authority to release such information outside of Rule 6(e), as some federal courts have held when applying the rule's federal counterpart. The Supreme Court, after determining that, despite the Governor's inability to satisfy the traditional standing requirement, it would consider the case because of the considerable public interest, disagreed with the Governor's arguments and held that: There is no inherent authority in the Superior Court to disclose grand jury materials beyond that which is permitted by the Superior Court Rules of Criminal Procedure. The Court also determined that, even had the Court held otherwise, it would have been well within the discretion of the Superior Court to deny the Governor's petition because the relevant cases on which the Governor relied in support of disclosure involved circumstances so unlike those presented in this case. Therefore, the Court affirmed the judgment of the Superior Court.