Justia Rhode Island Supreme Court Opinion Summaries

In the late 1980s, Ronald Koziol purchased property in Central Falls, Rhode Island, zoned for heavy industrial use. In 1992, the zoning changed to residential, making the existing automotive repair business a legal nonconforming use. In 2022, Koziol Firearms, Inc. was formed to operate a firearms business on the property. The City’s zoning official denied the request, stating the property was in a residential zone, requiring a use variance. The Zoning Board of Review denied the variance application, and the plaintiff appealed to the Superior Court, also seeking a declaratory judgment that the 1992 zoning amendment was invalid.The Superior Court denied the plaintiff’s motion to present additional evidence and dismissed the zoning appeal, finding the property had a viable use as an automotive repair business. The court dismissed the declaratory judgment count without prejudice, stating it lacked sufficient evidence to rule on the validity of the 1992 zoning amendment.The Rhode Island Supreme Court reviewed the case. The plaintiff argued the trial justice overlooked material evidence and that the zoning classification was in dispute. The City contended the case was moot, the plaintiff lacked standing, and the claim was barred by laches. The Supreme Court found the trial justice did not conduct necessary fact-finding for the declaratory judgment and remanded the case to the Superior Court for a new hearing to determine if the plaintiff should be granted declaratory relief. View "Koziol Firearms, Inc. v. Marchand" on Justia Law

Edgar Sepulveda, as Trustee of the 7 Half Mile Road Living Trust, claimed ownership of a disputed area of land through adverse possession. The land in question bordered his property at 7 Half Mile Road and the property of John Buffum and Angie Salem at 5 Half Mile Road. Sepulveda argued that he had maintained the disputed area exclusively for over ten years. Buffum and Salem, who purchased their property in 2018, disputed this claim and sought a declaratory judgment and damages for trespass.The Superior Court held a bench trial and found in favor of Buffum and Salem. The trial justice determined that Sepulveda's use of the disputed area began only when he installed a new driveway in 2016 or 2017, which did not meet the ten-year requirement for adverse possession. The court also found Sepulveda's testimony lacking in credibility and ruled that Buffum and Salem had proven their claims of trespass and were entitled to declaratory relief.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's judgments. The Supreme Court agreed with the trial justice's credibility assessments and found no clear error in the determination that Sepulveda failed to prove the elements of adverse possession. The court upheld the injunctions requiring Sepulveda to remove the encroaching driveway and prohibiting him from entering the disputed area. View "Sepulveda v. Buffum" on Justia Law

Matthew Moriarty, the defendant, appealed a Superior Court order dismissing his amended counterclaim against Evoqua Water Technologies LLC and Neptune-Benson, LLC. Moriarty's counterclaim sought declaratory relief and tort damages, alleging violations of a non-compete agreement he signed in 2010 while employed by Neptune-Benson, Inc. (NBI). Evoqua acquired Neptune-Benson in 2016 and hired Moriarty in 2017. The plaintiffs sued Moriarty in 2018 for breaching the 2010 agreement, among other claims, and obtained a preliminary injunction in 2019 to enforce the agreement.The Superior Court dismissed Moriarty's counterclaim, citing the litigation privilege for statements made during judicial proceedings. Moriarty's counterclaim included claims for emotional distress, declaratory judgments, constructive discharge, misrepresentation, and interference with business relations, based on alleged false testimony by an Evoqua executive during the preliminary injunction hearing.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's dismissal. The Court held that the litigation privilege protected the executive's testimony, barring Moriarty's claims for emotional distress, misrepresentation, and interference with business relations. The Court also found Moriarty's declaratory judgment claim moot, as the non-compete agreement had expired in 2020, and his constructive discharge claim failed to state a valid cause of action. The Court concluded that Moriarty did not demonstrate that his working conditions were so intolerable that a reasonable person would feel compelled to resign. Thus, the dismissal of Moriarty's amended counterclaim was upheld. View "Evoqua Water Technologies LLC v. Moriarty" on Justia Law

Alebia, Inc. (Alebia) is a Rhode Island corporation that owned a property at 284-286 Atwells Avenue, Providence. In September 2005, Carmela Natale and Walter Potenza, purported owners and shareholders of Alebia, executed a promissory note and mortgage in favor of Equity One Mortgage Company. The mortgage lacked a legal description of the property, but the loan proceeds were used to pay off prior mortgages and taxes on the property. The note was intended to be secured by the property, but Natale and Potenza signed the mortgage in their individual capacities instead of as corporate representatives of Alebia.In 2011, Deutsche Bank National Trust Company (Deutsche Bank), the current holder of the note, filed a complaint in Providence County Superior Court against Natale and Potenza for breach of contract and against Alebia seeking reformation of the mortgage. Deutsche Bank obtained a judgment against Natale and Potenza in 2017 but could not proceed against the property. In 2021, Deutsche Bank filed a motion to equitably reform the mortgage against Alebia. The Superior Court held remote evidentiary hearings and granted the motion, reforming the mortgage to reflect that Natale and Potenza signed as corporate representatives of Alebia.The Rhode Island Supreme Court reviewed the case. The court held that the Superior Court did not abuse its discretion in admitting testimony and evidence, including the promissory note. The court found sufficient evidence to support the reformation of the mortgage due to mutual mistake. The court also held that the mortgage could be reformed without reforming the note and that the remote hearings did not violate due process, despite the error in holding them remotely without consent. The Supreme Court affirmed the judgment of the Superior Court. View "Deutsche Bank National Trust Company v. Alebia, Inc." on Justia Law

The case involves a dispute over the possession of Touro Synagogue, the oldest active synagogue in the United States, located in Newport, Rhode Island. Congregation Shearith Israel (Shearith Israel) sought to evict Congregation Jeshuat Israel (Jeshuat Israel) from the synagogue. Shearith Israel sent a notice of termination to Jeshuat Israel, demanding they vacate the premises by February 1, 2023. Jeshuat Israel did not vacate, leading Shearith Israel to file an action for trespass and repossession by ejectment.The Rhode Island Superior Court ruled in favor of Shearith Israel, granting them the right to immediate possession of the property. Jeshuat Israel appealed, raising four arguments: the validity of the termination notice, the existence of a condition precedent in a 1945 agreement, the modification of a 1908 lease by the 1945 agreement, and the waiver of a defense by Shearith Israel.The Rhode Island Supreme Court reviewed the case. It found that the termination notice was valid and that the Superior Court had subject-matter jurisdiction. The court also determined that the 1945 agreement did not modify the lease to include a condition precedent requiring consultation before eviction. The agreement's requirement for consultation pertained only to matters of historical preservation and not to eviction actions. The court affirmed the Superior Court's judgment, granting Shearith Israel the right to take immediate possession of Touro Synagogue. View "Congregation Shearith Israel v. Congregation Jeshuat Israel" on Justia Law

In 2019, the Rhode Island Department of Corrections (DOC) implemented changes to its Absenteeism Management Program (AMP), citing abuse of the existing sick-time policy. The changes included new discipline tracks, sanctions for absenteeism, stricter sick note requirements, and closer scrutiny of pattern sick time use. The Rhode Island Brotherhood of Correctional Officers (RIBCO) requested bargaining over these changes, which the DOC refused, leading RIBCO to file an unfair labor practice charge.The Rhode Island State Labor Relations Board (SLRB) found that the DOC had committed an unfair labor practice by making substantial changes to working conditions without bargaining. The board rejected the DOC's defenses, including the argument that the changes were within the director’s statutory authority and the management-rights clause of the collective bargaining agreement (CBA).The DOC appealed to the Superior Court, which reversed the SLRB's decision. The Superior Court found that the board's decision was not supported by substantial evidence and that the changes were within the DOC director’s statutory authority under Rhode Island law.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's judgment. The Court held that the SLRB's decision was not supported by reliable, probative, and substantial evidence. It also agreed that the changes to the AMP were within the DOC director’s statutory authority under sections 42-56-10(2), (5), and (7) of the Rhode Island General Laws, which grant the director broad discretion in managing the department, maintaining safety and order, and disciplining employees. Thus, the DOC was not obligated to bargain over the AMP changes. View "State of Rhode Island v. Rhode Island State Labor Relations Board" on Justia Law

The plaintiff, Sara Roman, filed a complaint in Providence County Superior Court alleging she sustained injuries from slipping on untreated snow and ice at Dr. Martin Luther King Jr. Elementary School in Providence. She claimed negligence against the City of Providence and K. Scott Construction & Disposal, Inc., which had a contract with the city for snow removal.The Superior Court granted summary judgment in favor of both defendants. The first hearing justice ruled in favor of the city, applying the Connecticut Rule, which states that a landlord or business invitor's duty to remove snow and ice arises only after the storm has ceased and a reasonable time has passed. The second hearing justice ruled in favor of K. Scott, determining that K. Scott did not owe a duty to the plaintiff because it was not authorized to begin snow removal until after the plaintiff's fall.The Rhode Island Supreme Court reviewed the case. It vacated the judgment in favor of the city, finding that a question of material fact remained as to whether the plaintiff slipped on preexisting ice or freshly accumulated snow, which would affect the city's duty under the Connecticut Rule. The court affirmed the judgment in favor of K. Scott, holding that K. Scott did not owe a duty to the plaintiff at the time of the incident because it was not authorized to perform snow removal until after the plaintiff's fall. View "Roman v. The City of Providence" on Justia Law

In 1997, Christopher Thornton was convicted of multiple charges, including assault with a dangerous weapon, assault resulting in serious bodily injury, violating a no-contact order, kidnapping, and witness intimidation. He was sentenced to consecutive terms for each conviction. Thornton's convictions were upheld by the Rhode Island Supreme Court in 2002. He subsequently filed three unsuccessful petitions for postconviction relief. In 2015, Thornton filed a fourth petition, raising several claims.The Superior Court partially granted Thornton's fourth petition for postconviction relief, vacating his convictions for felony assault resulting in serious bodily injury and witness intimidation. The court found that the trial justice had failed to properly instruct the jury on the definitions of "serious bodily injury" and "criminal proceeding," which led to the vacating of these convictions. The state argued that Thornton's claims were barred by the doctrine of res judicata, as they could have been raised in his previous petitions.The Rhode Island Supreme Court reviewed the case and concluded that the Superior Court erred in granting postconviction relief. The Supreme Court held that Thornton's claims were indeed barred by the doctrine of res judicata, as codified in § 10-9.1-8, which precludes the relitigation of issues that could have been raised in prior proceedings. The court found no compelling reason to apply the interest-of-justice exception to Thornton's claims, as there was no newly discovered evidence or claim of actual innocence. Consequently, the Supreme Court quashed the portions of the Superior Court's amended judgment that vacated Thornton's convictions for felony assault resulting in serious bodily injury and witness intimidation. View "Thornton v. State of Rhode Island" on Justia Law

Ms. Rajmonda Mile attended her daughter’s wedding at Kirkbrae Country Club on September 9, 2018, where she allegedly slipped and fell. She filed a lawsuit against Kirkbrae in Providence County Superior Court and requested any photographs or videotapes of the incident. Kirkbrae acknowledged possessing a surveillance video of the incident but claimed it was protected under attorney work product privilege, referencing the case Cabral v. Arruda.The Superior Court denied Ms. Mile’s motion to compel the production of the video, agreeing with Kirkbrae’s assertion that the video was protected under the work product doctrine. Ms. Mile then sought review from the Rhode Island Supreme Court, arguing that the video was actual evidence of the incident and not created in anticipation of litigation.The Rhode Island Supreme Court reviewed the case and determined that the video was not protected under the work product privilege because it was recorded by Kirkbrae’s surveillance system at the time of the incident and not at the request of an attorney. The court emphasized that the burden of proving the applicability of the work product privilege lies with the party seeking to withhold the evidence. Since Kirkbrae failed to meet this burden, the trial justice’s denial of the motion to compel was deemed an error.The Rhode Island Supreme Court quashed the Superior Court’s order and remanded the case for further proceedings consistent with its opinion, instructing the lower court to compel the production of the video. View "Mile v. Kirkbrae Country Club" on Justia Law

Judith Clinton filed a complaint in the Superior Court for Washington County against Chad Babcock, Lisa Nelson, Regina Foster Bartlett, and Caryn Sullivan, alleging defamation and other misconduct that caused her reputational damage, emotional distress, and monetary losses. Clinton later amended her complaint to include Maria DiMaggio and Toastmasters International, adding a breach of contract claim against the latter. The Superior Court allowed Clinton to file a second amended complaint but denied her third and fourth motions to amend.The Superior Court granted the defendants' motion to enforce a dismissal stipulation and vacated a scheduling order. Clinton, who had been representing herself after unsuccessful attempts to secure new counsel, signed a Stipulated Agreement of Dismissal with all defendants, which was filed on December 13, 2022. Subsequently, the defendants filed a Stipulation of Dismissal on December 27, 2022, without notifying Clinton, who then alleged fraudulent conduct. The trial justice initially vacated the Stipulated Agreement of Dismissal and scheduled a trial date but later reconsidered this decision.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's order. The Supreme Court held that the trial justice properly reinstated the Stipulated Agreement of Dismissal, noting that the agreement was binding and could not be set aside without the consent of all parties, absent extraordinary circumstances such as fraud or mutual mistake. The court found no evidence of duress or other factors that would justify vacating the agreement. The Supreme Court also upheld the trial justice's decision to treat the defendants' motions as motions to reconsider, given the lack of proper notice to the defendants at the initial hearing. View "Clinton v. Babcock" on Justia Law