The Rhode Island Supreme Court vacated a Superior Court judgment that had reversed a District Court protection order, ordering a new hearing in a domestic violence case involving Alicia Andrew and Richard Adorno.

Justice Long, writing for the court, announced the decision in *Andrew v. Adorno* (R.I. 2025), after the case proceeded through the court's expedited summary decision process. The five-justice panel, including Chief Justice Suttell and Justices Goldberg, Robinson, Lynch Prata, and Long, unanimously decided the appeal without requiring full briefing or oral argument.

The case originated on Feb. 16, 2024, when Andrew filed a domestic-abuse complaint in District Court alleging that Adorno had "caused [her] to engage involuntarily in sexual relations by force, threat of force, or duress." The District Court granted an ex parte temporary protection order the same day, prohibiting Adorno from contacting Andrew and requiring him to surrender any firearms in his possession.

Following standard procedure in protection order cases, the District Court scheduled a hearing to determine whether to make the temporary order permanent. The court record indicates that after this initial hearing process, the District Court granted Andrew a final protection order against Adorno.

Adorno subsequently appealed the District Court's decision to the Superior Court, which has appellate jurisdiction over District Court protection order cases under Rhode Island law. The Superior Court reversed the District Court's judgment, effectively eliminating the protection order that had been in place.

Andrew then appealed the Superior Court's reversal to the Rhode Island Supreme Court, the state's highest court. The Supreme Court issued an order directing both parties to appear and show cause why the case should not be decided summarily, rather than through the standard appellate process requiring full briefs and oral arguments.

This "show cause" procedure allows the Supreme Court to expedite cases that may not require extensive briefing when the legal issues are straightforward or when justice requires prompt resolution. Both parties submitted written materials and appeared for oral presentations before the court.

After reviewing the parties' submissions and the complete trial record, the Supreme Court concluded that "cause has not been shown" for the case to proceed through regular appellate channels. The court determined it could resolve the matter based on the existing record without additional briefing or argument.

In its decision, the Supreme Court found sufficient grounds to vacate the Superior Court's reversal of the protection order. Rather than reinstating the original District Court order, however, the Supreme Court remanded the case "for a new hearing."

This remedy suggests the Supreme Court identified procedural or substantive issues with either the original District Court proceedings or the Superior Court's review that warrant fresh consideration of the evidence. A remand for new hearing typically occurs when appellate courts determine that lower courts did not properly apply legal standards, consider relevant evidence, or follow appropriate procedures.

The decision represents a victory for Andrew, who will have another opportunity to seek protection order relief in the District Court. The remand means the case will return to the trial court level, where Andrew can present her case again before a District Court judge.

Protection orders in Rhode Island domestic violence cases require plaintiffs to prove by a preponderance of evidence that domestic abuse occurred or is likely to occur. These orders can include provisions prohibiting contact, requiring the defendant to stay away from the plaintiff's residence or workplace, and mandating surrender of firearms.

The case highlights the multi-tiered review process available in Rhode Island's court system for protection order cases. District Courts handle initial petitions and hearings, with appeals going first to Superior Court and potentially to the Supreme Court.

Rhode Island law provides various forms of relief for domestic violence victims, including temporary and final protection orders. The statutory framework allows courts to enter emergency ex parte orders when immediate protection is necessary, followed by hearings where both parties can present evidence.

The Supreme Court's decision to use its expedited summary process indicates the court viewed the case as requiring prompt resolution, possibly due to the ongoing safety concerns inherent in domestic violence protection order cases.

With the case now remanded to District Court, Andrew will have the opportunity to present her allegations again in a new hearing. The District Court will need to consider the evidence anew and determine whether the statutory standards for granting a protection order have been met.

The remand order does not indicate what specific issues the Supreme Court found with the previous proceedings, as the full opinion details were not included in the court record. However, the decision to vacate rather than affirm suggests the Superior Court's reversal was not supported by the law or evidence presented.

This case demonstrates the Rhode Island court system's commitment to ensuring proper procedures are followed in domestic violence protection order cases, where the stakes for victim safety can be extraordinarily high and require careful judicial review at multiple levels.