Justia Rhode Island Supreme Court Opinion Summaries

A federally certified organization dedicated to providing comprehensive health and social services to elderly individuals, primarily those eligible for Medicaid, relocated its operations to East Providence and sought a property tax exemption for its new location. The organization asserted that nearly all its participants are low-income elderly and claimed eligibility for exemption under a state statute that provides tax-exempt status for property used for the aid or support of the aged poor, among other categories. After purchasing the property, the organization applied for the exemption, arguing that the statutory language supported its claim. The local tax assessor denied the application, finding that the organization was not one of the specifically enumerated entities—such as a library or a nonprofit hospital—under the statute, and that its mission was not limited to supporting only the aged poor.The organization appealed this denial to the East Providence Tax Board of Assessment Review, which affirmed the assessor’s decision. Subsequently, the organization brought the case to the Providence County Superior Court, where both parties filed cross-motions for summary judgment. The Superior Court found the statute ambiguous and, applying principles of statutory construction, concluded that the exemption applied only to the specific types of entities listed in the statute, all of which must use their property exclusively for the designated purposes. The court granted summary judgment in favor of the tax assessor.On appeal, the Supreme Court of Rhode Island reviewed the statutory language and agreed that it was ambiguous but held that, under Rhode Island law, tax exemption statutes must be strictly construed in favor of taxation. Consequently, any ambiguity must be resolved against the taxpayer. The Supreme Court affirmed the Superior Court’s judgment in favor of the tax assessor. View "Pace Organization of Rhode Island v. Frew" on Justia Law

The case involves a fatal shooting that occurred during an attempted marijuana purchase in Providence, Rhode Island. The defendant accompanied a friend to buy marijuana from the decedent, who required purchasers to provide identification. The defendant entered the decedent’s car with a firearm, allegedly for protection, and a struggle ensued inside the vehicle. During the altercation, the firearm discharged, resulting in the decedent’s death. The defendant claimed that the shooting was accidental and that he acted in fear during the struggle. After the incident, the defendant returned to his friend’s car and left the scene.The Superior Court conducted a jury trial in which the defendant was convicted of second-degree murder, discharging a firearm while committing a crime of violence, and carrying a pistol without a license. The defendant moved for a new trial, arguing that the verdict was against the weight of the evidence and that the trial justice made errors, including factual misstatements about his role in the events and reliance on facts not in evidence. The trial justice denied the motion, finding the jury’s verdict justified and crediting prosecution witnesses, but mistakenly referred to the defendant as a drug dealer and seller, which was not supported by the record, and referenced evidence not presented at trial.The Supreme Court of Rhode Island reviewed the appeal. It found no error in the exclusion of certain testimony under the State v. Harnois line of cases. However, the Supreme Court determined that the trial justice’s mischaracterization of the defendant’s role and reliance on facts outside the evidence constituted clear error. The Supreme Court vacated the order denying the motion for a new trial and remanded the case for a new hearing on the motion for a new trial in the Superior Court. View "State v. Garcia" on Justia Law

The plaintiff acquired property in Exeter, Rhode Island, in 1997 and later sought to develop a solar farm on it. To proceed, he needed legal access from a public road. A town map suggested such access via an extension of Estate Drive, but in reality, no road existed there—only undeveloped woods, which the town considered a “paper street.” The plaintiff attempted to clear and gravel the area without town approval, prompting the town to block access and send a cease-and-desist letter. The planning board denied his development application, and the zoning board affirmed. The plaintiff then filed multiple lawsuits, including one seeking a declaration that the disputed area was a public road, and later, claims for due process violations and, after losing on the road status issue, for adverse possession and related theories regarding ownership and access.The Superior Court first denied the town’s motion for judgment on the pleadings in the due process case and then denied the town’s motion to dismiss the adverse possession case. The trial justice reasoned that res judicata and collateral estoppel did not apply because, in her view, the facts and legal theories in the new cases were different from the previously litigated issues, such as whether the area was a public road. She further concluded that the town had acquiesced to separate lawsuits and that Davis was not barred from asserting inconsistent or alternative claims in later litigation.The Supreme Court of Rhode Island reviewed both cases on certiorari. The Court held that res judicata barred the plaintiff’s claims because all arose from the same set of facts concerning access to the disputed area and could have been raised in the initial litigation. The Court further concluded that collateral estoppel and judicial estoppel also precluded the plaintiff’s adverse possession and related claims, as key factual issues had already been determined. The Court quashed the Superior Court’s orders and remanded for dismissal of both cases. View "Davis v. Wood Estates, Inc." on Justia Law

The plaintiff, an individual residing overseas, alleged that his longstanding debit card account with the defendant bank was improperly deactivated on multiple occasions, including after a series of withdrawals he used to pay rent in Mauritius. He claimed that the bank’s customer service was difficult to navigate and that the deactivation caused him mental anguish and damages. He sought damages and injunctive relief, asserting the bank had a duty to restore his access and protect against fraud without jeopardizing customers.The defendant moved to dismiss the complaint in the Kent County Superior Court. The plaintiff, who was self-represented, filed a motion seeking permission to appear remotely by WebEx for the hearing on the defendant’s motion to dismiss. The Superior Court docket indicated that his motion to appear remotely was not scheduled because he did not request a hearing date. Subsequently, the plaintiff filed a notice of appeal, identifying the docket entry regarding his unscheduled motion as the order appealed from. After this, the Superior Court granted the defendant’s motion to dismiss the complaint.The Supreme Court of Rhode Island reviewed the plaintiff’s appeal, which focused on the denial of his motion to appear remotely and broader challenges to the Superior Court’s in-person appearance requirements. The Supreme Court held that the appeal was procedurally improper because the plaintiff did not appeal from an appealable final judgment, order, or decree, but rather from a non-appealable docket entry. The Court therefore denied and dismissed the appeal, and the case may be remanded to the Superior Court. The Court also noted that the discretion to permit remote appearances lies with the trial justice under the Superior Court Rules of Civil Procedure. View "LaPadula v. Citizens Financial Group, Inc." on Justia Law

A petitioner sought temporary custody of her nephew, a Guatemalan-born minor, after he entered the United States and was released to her care by the Office of Refugee Resettlement. The petitioner, the child's maternal aunt, resided with him in Central Falls, Rhode Island. She was granted guardianship by the Central Falls Probate Court and then filed a petition with the Rhode Island Family Court for temporary custody and special findings of fact, which were necessary for her nephew’s Special Juvenile Immigration petition. The petition was filed before the child’s eighteenth birthday but was not heard until after he turned eighteen. The biological parents consented to the proceedings and did not oppose the petition.The case was first considered by a magistrate of the Family Court, who, after noting that the child had turned eighteen before the hearing, determined that the court lacked subject-matter jurisdiction because its statutory authority extended only to persons under eighteen. The magistrate dismissed the petition and found that the court could not issue an order nunc pro tunc to the petition’s filing date. On appeal to the Chief Judge of the Family Court, the decision was upheld, with the Chief Judge concurring that the court lacked jurisdiction once the child was no longer a minor under Rhode Island law.The Supreme Court of Rhode Island reviewed the appeal. The Court held that, under the statutory framework in effect at the time of the hearing, the Family Court did not have subject-matter jurisdiction because the individual was no longer under eighteen years of age. The Court also rejected the petitioner’s arguments for nunc pro tunc relief and for retroactive application of a subsequent statutory amendment. The Supreme Court affirmed the Family Court’s dismissal of the petition. View "In re DDH" on Justia Law

In the early hours of January 24, 2022, the defendant fatally shot one individual and seriously injured another outside a nightclub in Pawtucket, Rhode Island. He did not dispute that he fired the shots, but claimed at trial that he acted in defense of his cousins, whom he believed were in imminent danger after a physical altercation. The incident was captured on video, which at certain points contradicted the defendant’s account. During the trial, the main factual dispute centered on whether the defendant’s use of force was justified under the defense of others doctrine.The case was tried in the Providence County Superior Court. The jury found the defendant guilty of second-degree murder, discharging a firearm during a violent crime resulting in death, and firearm possession offenses, but acquitted him of charges related to the shooting of the second individual. The trial justice sentenced the defendant to a lengthy period of incarceration. During the trial, improper questions from the prosecutor regarding the defendant’s post-arrest silence were objected to and sustained, with the trial justice issuing cautionary instructions to the jury and ultimately denying the defense’s motion for a mistrial.On appeal, the Supreme Court of Rhode Island reviewed whether the trial justice erred in denying a mistrial after the prosecution impermissibly questioned the defendant about his exercise of the right to remain silent. The Supreme Court held that the prosecutor’s questions violated the defendant’s due process rights, as such use of post-arrest silence for impeachment is fundamentally unfair. The Court found that the cautionary instructions did not cure the prejudice resulting from these questions and concluded that a mistrial was warranted. Accordingly, the Supreme Court vacated the conviction and remanded the case for further proceedings. View "State v. Baker" on Justia Law

A woman was discovered dead and buried in a shallow grave on Crescent Beach in Riverside, Rhode Island, in June 1994. The investigation quickly focused on Gary Tassone after the victim’s estranged husband reported her missing and provided information connecting her to Tassone. Detectives interviewed Tassone, who gave several statements to police—initially denying, then repeatedly revising, his account of the night, ultimately admitting to being with the victim, striking her with a shovel, and leading police to evidence he claimed to have discarded. Physical evidence, including sand and personal items, further linked him to the crime scene. Tassone was indicted and charged with first-degree murder.The Superior Court held a suppression hearing and denied Tassone’s motion to suppress his confessions, finding he was not in custody at the outset and that his statements were voluntary, knowing, and intelligent waivers of his rights. At trial, the jury convicted Tassone of first-degree murder, finding the crime involved torture or aggravated battery, and he was sentenced to life without parole. The conviction was affirmed on direct appeal. Tassone later sought postconviction relief in the Superior Court, asserting ineffective assistance of counsel based on various alleged failures by trial counsel. After an evidentiary hearing, the Superior Court denied his application.On review, the Supreme Court of Rhode Island affirmed the Superior Court’s denial of postconviction relief. The Court held that Tassone failed to demonstrate that his counsel’s performance was objectively unreasonable or that any alleged deficiencies prejudiced his defense, given the overwhelming evidence of guilt, including his own detailed confessions and corroborating physical evidence. As a result, the judgment was affirmed. View "Tassone v. State of Rhode Island" on Justia Law

The taxpayers filed a joint Rhode Island personal income tax return for the 2017 tax year, claiming an overpayment and seeking a refund. The return was filed in July 2020, and the Rhode Island Division of Taxation processed it but denied the refund request. The Division cited Rhode Island General Laws § 44-30-87, stating the claim was not filed within the allowable time period and/or no tax was paid within the allowable period. The taxpayers requested an administrative hearing, after which the hearing officer concluded they were not entitled to the refund, and the tax administrator adopted this decision.Following the administrative denial, the taxpayers appealed to the Rhode Island District Court. The hearing judge considered cross-motions for summary judgment and ruled in favor of the taxpayers. The judge found the statutory language ambiguous and interpreted the three-year limitation period for refunds as referring to taxes paid during the three years immediately preceding the refund request, rather than the three years following the filing of the return. Judgment was entered for the taxpayers, and the case was remanded to the Division of Taxation for further proceedings. The Division then petitioned the Rhode Island Supreme Court for a writ of certiorari.The Supreme Court of Rhode Island reviewed the case de novo, focusing solely on the statutory interpretation of § 44-30-87(a). The Court held that the three-year refund period refers to the three years following the filing of the tax return, and that any refund is limited to the portion of tax paid within those three years. The Court quashed the District Court’s judgment, finding that the lower court erred in its interpretation of the statute, and returned the record to the District Court with its decision. View "Schmidt v. Rhode Island Division of Taxation" on Justia Law

The defendant was involved in a fatal shooting that followed a drug transaction in Providence, Rhode Island, on April 22, 2021. He was a longtime drug dealer and, on the night in question, sold cocaine to a woman with her boyfriend (the decedent) present. During and after the transaction, the decedent became agitated, shouting threats at both the defendant and the woman. The confrontation escalated when the decedent approached the defendant’s car, yelled additional threats, and appeared to hold an object the defendant believed to be a firearm. The defendant then shot the decedent in the chest, fled the scene, and later disposed of evidence.The case was tried in the Providence County Superior Court. Before trial, the defendant pleaded guilty to two firearm-related charges that were not presented to the jury. At trial, he asserted self-defense and requested that the jury be instructed on the lesser-included offense of voluntary manslaughter, arguing that the evidence supported a finding that he acted in the heat of passion due to adequate provocation. The trial justice denied this request, finding the defendant’s demeanor and testimony showed he was calm and not provoked to the extent required by law. The jury convicted the defendant of second-degree murder and discharging a firearm during a crime of violence. The trial justice imposed consecutive life sentences and additional terms for the firearm charges.The Supreme Court of Rhode Island reviewed the case. It held that there was insufficient evidence to warrant a voluntary manslaughter instruction because the facts did not support finding adequate provocation or sudden heat of passion. The court further declined to consider the defendant’s argument regarding the excessiveness of his sentence because he failed to seek sentence revision under Rule 35 in the Superior Court. The Supreme Court affirmed the judgment of conviction. View "State v. Xaykosy" on Justia Law

Two individuals, Nazaski Carrasco-Smith and Devin Delacruz, were shot while sitting in a vehicle in Providence, Rhode Island, on December 4, 2020. Carrasco-Smith survived; Delacruz did not. The investigation led police to a rented Nissan Altima and uncovered connections between the defendant, his girlfriend, and others through surveillance footage, GPS tracking, and extensive cell phone data analysis. Police also discovered a GPS tracker on Carrasco-Smith’s vehicle and recovered incriminating text messages between the defendant and his girlfriend, some of which contained accusations related to the murder.After a grand jury indictment, the case proceeded to trial in the Providence County Superior Court. The state presented forensic and digital evidence as well as expert testimony on local gang rivalries, suggesting a motive. During the trial, the prosecution introduced text messages from the defendant’s girlfriend accusing him of involvement in the murder. The defendant moved to exclude these messages, arguing they were hearsay and unfairly prejudicial. The trial justice denied the motion, admitted the messages, and issued cautionary instructions to the jury. The jury convicted the defendant on all counts, including first-degree murder and multiple firearm offenses. The defendant moved for a new trial, which was denied, and was sentenced to consecutive life terms and additional concurrent sentences.The Supreme Court of Rhode Island reviewed the case. It held that the trial justice abused her discretion by admitting the girlfriend’s accusatory text messages, finding that their probative value was substantially outweighed by their prejudicial effect under Rule 403 of the Rhode Island Rules of Evidence. The court determined that the cautionary instructions given did not cure the prejudice and that the error was not harmless in light of the prosecution’s emphasis on the messages. The court vacated the conviction and remanded for a new trial. View "State v. Chandler" on Justia Law