Justia Rhode Island Supreme Court Opinion Summaries

A man was convicted of two counts of first-degree child molestation based on events that began in 2005, when the complainant was ten years old. The complainant, who lived with her mother, became acquainted with the defendant through her older sister and neighbors. After the defendant briefly lived with the complainant’s mother and had a short romantic relationship with her, the defendant and the complainant began spending time together. Their interactions gradually became more physical, progressing to frequent sexual activity, including digital and penile-vaginal penetration, while the complainant was still under fourteen years old. These acts occurred both while the complainant’s mother was at home and during times when she was absent, such as a week-long hospital stay.After several years and a disclosure to her mother and others, the complainant’s allegations were reported to the Rhode Island State Police. The defendant was interviewed by detectives at police headquarters. During the interview, after being informed of his Miranda rights, the defendant invoked his right to counsel, and questioning ceased. However, outside the station, the defendant initiated further conversation with the detective, during which he made incriminating statements. The defendant was later indicted in 2016 after earlier grand jury proceedings did not result in charges.The Rhode Island Superior Court denied the defendant’s motion to suppress his statements to police, finding he was not in custody outside the station and that, even if he had been, he reinitiated contact and knowingly waived his rights. The court also denied his motion for judgment of acquittal, determining that the complainant’s testimony sufficiently established penetration within the charged timeframes.The Supreme Court of Rhode Island affirmed the Superior Court’s judgment. The court held that the trial justice did not err in denying the motion to suppress, as the defendant reinitiated contact and voluntarily waived his rights. The court also upheld the denial of the motion for judgment of acquittal, finding the evidence was sufficient for a reasonable juror to convict. View "State v. Carreiro" on Justia Law

A juvenile was charged in Newport County Family Court with two counts of first-degree child molestation, based on sexual acts he engaged in with a minor who was twelve years old at the time. Prior to trial, a competency hearing was held. Two experts in forensic psychology evaluated the respondent and testified that he had limited understanding of the legal process, particularly about sex offender registration, plea bargains, and the role of the prosecutor. Their report concluded that he did not sufficiently demonstrate factual or rational understanding or adequate decision-making abilities. However, the respondent had no prior mental health diagnoses, cognitive impairments, or psychiatric history.The Family Court judge considered the expert testimony and report but concluded that the respondent’s answers, while imperfect, demonstrated a sufficient understanding of the proceedings and the ability to assist in his defense. The judge found the respondent competent to stand trial. Following a bench trial, the respondent was found delinquent on both counts beyond a reasonable doubt. At sentencing, an expert social worker recommended against sex offender registration, describing the respondent as non-predatory and not a danger to the community. The judge rejected this recommendation, citing deficiencies in the expert’s knowledge of the case facts and the circumstances of the offenses.On appeal, the Supreme Court of Rhode Island reviewed the Family Court’s findings. The Court held that the trial justice did not abuse her discretion in finding the respondent competent, as the trial judge is the ultimate factfinder on competency and need not accept uncontradicted expert testimony. The Court also held that the trial justice did not err or abuse her discretion in imposing the full fifteen-year sex offender registration period, finding the respondent’s conduct was criminal not solely because of the victim’s age but also because of his actions. The orders of the Family Court were affirmed. View "In re E.G.S" on Justia Law

A school committee in a Rhode Island town responded to community members’ concerns about racial inequity in district policies and staff diversity by voting to create an advisory group, later called the BIPOC Advisory Board. This Board was facilitated by a third-party organization under contract with the committee, with meetings initially open only to those identifying as BIPOC. The Board’s role was to discuss and make suggestions about district policies, which it conveyed to a policy sub-committee that, in turn, could submit proposals to the school committee. The Board had no authority to make binding decisions or directly implement policy changes. The school committee funded the facilitation of the meetings but did not compensate Board members.After being denied access to Board meetings, a plaintiff filed a complaint with the Rhode Island Office of the Attorney General, arguing that the Board was a public body subject to the Open Meetings Act (OMA). The Attorney General found that the Board was not a public body under the OMA. The plaintiff then filed suit in the Providence County Superior Court, seeking declaratory relief. The Superior Court denied the plaintiff’s motion for summary judgment and granted summary judgment to the school committee, finding that the Board was not a public body under the OMA. The court reasoned that the Board had no voting or veto power and that the policy review process provided public opportunities for input.On appeal, the Supreme Court of Rhode Island affirmed the Superior Court’s judgment. The Court held that the Board was not a public body subject to the OMA because it was an amorphous, ad hoc advocacy group without authority to make or veto policy decisions. The Court emphasized that the Board’s informal structure, lack of consistent membership, and merely advisory role did not trigger open meetings requirements under Rhode Island law. View "Solas v. South Kingstown School Committee" on Justia Law

After the death of Harry Fairhurst in 2019, his will—executed in 1981 with a 1997 codicil—left his estate equally to his seven children and named two of them as co-executors. The main asset was the family home. The will allowed the co-executors to sell estate assets without probate court approval, provided all children were notified by mail of their option to purchase. In 2020, the co-executors notified the devisees that the property was available, but the letter omitted key sale terms. No child responded. Subsequently, William, one of the co-executors, purchased the property for $260,000, using part of his share as an advance toward the purchase price, despite a higher bank appraisal and market analysis.Three siblings objected to the accounting of the sale in Cumberland Probate Court, focusing on the valuation and terms. The probate court, without hearing argument, found the sale invalid and illegal because the co-executors had not sought probate court approval, as required by Rhode Island General Laws § 33-19-9. The property was ordered to remain with the estate. The co-executors appealed to Providence County Superior Court, arguing the will authorized the sale without court approval and that the probate court’s sua sponte action violated their due process rights. Both sides moved for summary judgment.The Supreme Court of Rhode Island reviewed the case on appeal. It held that, regardless of the will’s language, § 33-19-9 required probate court approval for a co-executor’s private purchase of estate property to prevent self-dealing and ensure fairness. The Court found the will’s contrary provision invalid to the extent it conflicted with the statute and rejected the co-executors’ due process and laches arguments. The Supreme Court affirmed the Superior Court’s judgment, upholding the voiding of the sale. View "Fairhurst v. Fairhurst" on Justia Law

A dispute arose following a failed real estate transaction involving the sale of a hotel property in Warwick, Rhode Island. The property was to be sold by Shiva, LLC, of which Jay Patel was the registered agent, to LandingPartners LLC under a Purchase and Sale and Discounted Pay-Off Agreement. Centreville Bank held a mortgage on the property, which was in default. When Shiva, Airport Hospitality (another entity linked to Patel), and Patel failed to respond to an earlier lawsuit brought by LandingPartners, the Superior Court entered a default judgment against them, ordering specific performance of their obligations under the agreement and appointing a commissioner to facilitate the closing. Afterward, LandingPartners and Centreville Bank reached a consent order with new terms for the sale and discharged the mortgage, and the case was dismissed with prejudice.Shortly after the dismissal of the first case, Patel filed a new lawsuit in the Washington County Superior Court against LandingPartners, Centreville, and a related entity, 1850 Post Road Owner LLC. He alleged violations of the agreement, fraud, misrepresentation, unjust enrichment, and breach of the implied covenant of good faith and fair dealing. The defendants moved to dismiss, arguing the claims were barred by res judicata because they arose from the same transaction addressed in the prior litigation. The Superior Court agreed, finding that the parties or their privies were the same, the issues arose from the same transaction, and there was a final judgment in the first action.The Supreme Court of Rhode Island affirmed the Superior Court’s judgment. The Court held that res judicata barred Patel’s claims, as all issues now raised were or could have been raised in the initial suit, and the new claims concerned the same transaction. The dismissal of Patel’s complaint with prejudice was therefore upheld. View "Jay Patel v. LandingPartners LLC et al." on Justia Law

An employee who worked for a state agency in Rhode Island and regularly used her own personal vehicle for job-related travel was injured in a car accident caused by an underinsured driver. On the day of the incident, no state-owned vehicle was available, so she drove her own car. Her employer, the State of Rhode Island, carried a commercial auto insurance policy with Travelers Property Casualty Company of America, which provided liability coverage for employees using any vehicle within the scope of employment but only provided uninsured/underinsured motorist (UM/UIM) coverage when employees were occupying state-owned vehicles.After the accident, the employee sought UM/UIM benefits from Travelers, but her claim was denied because she was not occupying a covered auto under the policy. She brought suit in Providence County Superior Court, alleging breach of contract, seeking declaratory judgments on coverage, and pursuing bad faith and punitive damages. Travelers removed the case to federal court. The United States District Court for the District of Rhode Island granted summary judgment to Travelers, finding the policy language unambiguously did not provide the coverage she sought, and that Rhode Island law did not otherwise require it.On appeal, the United States Court of Appeals for the First Circuit certified two questions to the Supreme Court of Rhode Island: whether, under Rhode Island law and the precedent of Martinelli v. Travelers Insurance Companies, an employee using her own car within the scope of employment must be considered a named insured for UM/UIM coverage despite contrary policy terms; and whether it violates the Rhode Island Uninsured Motorist Statute or public policy for an employer’s policy to provide liability but not UM/UIM coverage in these circumstances.The Supreme Court of Rhode Island answered both questions in the negative, holding that neither the Martinelli precedent nor Rhode Island law required the employee to be treated as a named insured, and that the statutory and public policy requirements were not violated by the policy’s terms. View "Roberge v. Travelers Property Casualty Company of America" on Justia Law

A tenant and her young son resided in a rental property owned by a landlord. The tenant failed to pay rent for August 2024, prompting the landlord to file an eviction action in the Rhode Island District Court for nonpayment. The District Court held a hearing, after which it awarded possession to the landlord and entered a damages judgment against the tenant. The tenant appealed to the Superior Court, raising an affirmative defense and counterclaim based on alleged uninhabitability of the premises due to plumbing problems and a sewage fly infestation.While the appeal was pending in the Superior Court, the landlord moved to dismiss the appeal, arguing that the tenant’s failure to pay a prorated portion of September rent (covering the period after judgment in District Court but before the next rent due date) mandated dismissal under the Residential Landlord and Tenant Act. The tenant conceded nonpayment of that portion but argued the statute only required payment of full rent due after the appeal was taken, which she had paid in October. The Superior Court agreed with the landlord and dismissed the appeal.The Supreme Court of Rhode Island granted certiorari and reviewed the statutory interpretation. The Court held that under the plain language of the relevant statutes, a tenant appealing an eviction judgment is obligated to pay rent only on the next scheduled due date after the appeal is filed, not a prorated portion for days between judgment and the next rent due date. The Court further held that after the tenant vacated the apartment, the case ceased to be an action for recovery of real property, and the statutory rent-payment requirement no longer applied. The Supreme Court quashed the Superior Court’s order of dismissal and remanded the case for further proceedings on damages. View "Pioneer Investments, LLC v. McKiernan" on Justia Law

After obtaining a judgment in the amount of $109,250 plus interest and costs against a defendant, the plaintiff sought to collect the judgment by garnishing the defendant’s wages from her employer, a corporation. The employer was served with a writ of attachment but failed to timely file legally valid affidavits regarding the defendant’s wages, as required by statute. The plaintiff then moved to hold the employer liable for the full amount of the judgment, arguing that the statutory requirements for affidavits had not been satisfied. During the course of proceedings, the defendant passed away, and the employer ultimately provided affidavits with valid notarization and tendered the garnished wages to the plaintiff.A justice of the Providence County Superior Court initially granted the plaintiff’s first motion to charge the employer the full amount of the judgment, but, after the employer moved to vacate, that order was set aside. The plaintiff filed a second motion to charge the employer, again asserting that the statutory requirements had not been met. At hearings on the second motion, the plaintiff conceded that the employer had not refused or neglected to supply the required account of wages. The hearing justice found that the employer had provided the necessary information and that the plaintiff had received all wages withheld before the defendant’s death, resulting in no injury to the plaintiff. The court denied the second motion to charge.On appeal, the Supreme Court of Rhode Island affirmed the Superior Court’s decision. The Court held that, under the relevant statute, a garnishee can only be held liable for the full judgment if it “refuses or neglects” to provide the required sworn account. Because the plaintiff conceded there was no such refusal or neglect, and the plaintiff received all garnished wages, the statutory prerequisites for liability were not met. The Court therefore affirmed the denial of the plaintiff’s motion to charge the employer. View "Strassman v. Howe" on Justia Law

The case involves a legal malpractice claim related to the representation of a marina in a property tax dispute with a city. The marina, owned by a corporation for which John H. Williams is president and sole stockholder, retained Attorney Elizabeth McDonough Noonan and her law firm to handle ongoing tax matters in 2010. The attorney-client relationship ended no later than February 2017, when new counsel took over the representation and Attorney Noonan transferred all relevant files. Over three years later, in April 2020, the marina and Mr. Williams filed a complaint alleging negligent legal services and breach of contract related to the handling of the tax dispute.After discovery, the defendants moved for summary judgment in the Kent County Superior Court, arguing that the claims were barred by the three-year statute of limitations for legal malpractice, that Mr. Williams lacked standing to sue individually, and that the plaintiffs failed to provide expert evidence on the standard of care. The Superior Court granted summary judgment to the defendants. The court found that Mr. Williams was not a client in his individual capacity, the statute of limitations had expired, expert testimony was required and lacking, and there was no causation.On appeal, the Supreme Court of Rhode Island reviewed the Superior Court’s decision de novo. The Supreme Court held that the statute of limitations began no later than February 15, 2017, when the attorney-client relationship ended, and the complaint filed in April 2020 was untimely. The Court found that the discovery rule exception did not apply because the plaintiffs were aware of the relevant facts during the representation. The Supreme Court affirmed the judgment of the Superior Court. View "Williams v. Noonan" on Justia Law

The plaintiffs operated a daycare center that participated in a federally funded nutrition program administered by the Rhode Island Department of Elementary and Secondary Education. After several years in the program, they received a notice of proposed termination due to alleged serious deficiencies, such as inaccurate meal counts and noncompliance with meal requirements. The plaintiffs requested and received an administrative review, which resulted in a decision upholding their termination from the program, citing uncorrected deficiencies and failure to participate in required training.Following the administrative review, the plaintiffs filed an appeal in the Rhode Island Superior Court, challenging the administrative decision on the grounds that it was unsupported by the record and that mitigating evidence had not been considered. They also argued that the notice of termination failed to inform them of their right to a hearing, in violation of federal regulations. That appeal was pending when, several years later, the plaintiffs brought a second lawsuit in the Superior Court, this time alleging discriminatory disparate treatment and impact under the Rhode Island Civil Rights Act. They claimed that the state agency failed to provide the same level of instruction and feedback as it did to white-owned entities and did not offer materials in Spanish, resulting in harm due to their Hispanic ethnicity.The Rhode Island Superior Court granted the agency’s motion to dismiss the second lawsuit, finding that it was barred by res judicata because the plaintiffs could have raised their discrimination claims in the earlier administrative proceeding. On appeal, the Supreme Court of Rhode Island affirmed the judgment, holding that the plaintiffs had a full and fair opportunity to litigate their discrimination claims before the administrative review officer. The Court concluded that no exception to res judicata applied and that the plaintiffs’ complaint was properly dismissed. View "El Bebe Day Care Center, Inc. v. Rhode Island Department of Elementary and Secondary Education" on Justia Law