Justia Rhode Island Supreme Court Opinion Summaries

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

A deputy sheriff employed by the Rhode Island Department of Public Safety applied for both ordinary and accidental disability retirement pensions, claiming a back injury sustained in 2011 caused him to stop working in 2020. The Employees’ Retirement System of Rhode Island’s Disability Committee recommended approval of only the ordinary disability pension, finding the accidental disability claim untimely under the statutory filing limits, and noting no evidence of an intervening injury or aggravation. The state retirement board adopted this recommendation and denied the accidental disability pension. Despite submitting additional evidence and requesting rehearing and further medical evaluation, the deputy sheriff’s application continued to be denied by the board, which advised that any appeal could be made in the Superior Court or the Workers’ Compensation Court, if applicable.Following these denials, the deputy sheriff filed appeals in both the Superior Court and the Workers’ Compensation Court. The Employees’ Retirement System moved to dismiss the Workers’ Compensation Court matter, arguing that the court lacked jurisdiction over a state employee’s appeal. The trial judge of the Workers’ Compensation Court denied the motion, concluding that jurisdiction existed based on multiple statutes, including those relating to injured-on-duty payments and the right to appeal denials of accidental disability pensions.The Supreme Court of Rhode Island reviewed the case on certiorari and held that the Workers’ Compensation Court did not have subject matter jurisdiction to hear the deputy sheriff’s appeal. The Court reasoned that the statutory scheme provides for Workers’ Compensation Court jurisdiction only for municipal employees covered under the Optional Retirement Plan, not for state employees like the petitioner, who are covered by the state retirement system. The Supreme Court therefore quashed the trial judge’s order and remanded the case for dismissal due to lack of jurisdiction. View "O'Connell v. Employees' Retirement System of Rhode Island" on Justia Law

The dispute concerns neighboring property owners in South Kingstown, Rhode Island. The plaintiffs purchased their home in 2010, and the defendant purchased the adjoining lot in 2021. The contested area, approximately 1,134.9 square feet, is included in the defendant’s deed, but the plaintiffs asserted that they had used and maintained it as their own for over a decade, engaging in activities such as planting grass and trees, mowing, and storing items. The defendant’s property was vacant until he moved in, and tensions arose after he objected to the plaintiffs’ continued use of the area and eventually erected a fence.Following the defendant’s acquisition and subsequent dispute, the plaintiffs initiated a suit in the Washington County Superior Court, seeking title by adverse possession, acquiescence, or a prescriptive easement. The Superior Court conducted a bench trial, during which testimony was heard from both parties, the developer, and an expert. After trial, the judge found the defendant’s evidence more credible, particularly noting conversations in which the plaintiffs acknowledged the superior title of the prior owner by inquiring about purchasing the disputed property and seeking permission for certain uses. The court determined that the plaintiffs had not demonstrated hostile possession or a recognized boundary for the requisite ten-year period.The Rhode Island Supreme Court reviewed the Superior Court’s findings under a deferential standard, considering whether the lower court’s factual determinations were clearly erroneous. The Supreme Court affirmed the judgment, holding that the plaintiffs failed to establish by clear and convincing evidence the elements of adverse possession, acquiescence, or prescriptive easement, specifically the requirements of hostility and recognition of a boundary. The Supreme Court also found that the trial court’s findings were sufficiently detailed under the applicable procedural rule. The judgment for the defendant was affirmed. View "Blechman v. Woodward" on Justia Law

The plaintiff owned a vacant parcel in Westerly, Rhode Island, and sought to construct a single-family home. To do so, he needed approval from the Department of Environmental Management (DEM) for an onsite wastewater treatment system (OWTS). He applied for a variance from DEM’s regulations, asserting that his proposed system satisfied the general standard for granting variances. However, DEM denied the variance because the property’s water table was at zero inches from the original ground surface, failing to meet a specific regulatory requirement.After DEM’s denial, the plaintiff did not appeal to DEM’s Administrative Adjudication Division (AAD), arguing that such an appeal would be futile since the AAD purportedly lacked discretion to overturn the denial and could not adjudicate constitutional claims. Instead, he filed suit in the Superior Court, seeking declaratory, injunctive, and monetary relief, asserting both as-applied and facial challenges to the OWTS regulations under the Takings, Due Process, and Equal Protection Clauses of the state and federal constitutions. The state moved to dismiss, arguing failure to exhaust administrative remedies and the lack of constitutional violations. The Superior Court granted the state’s motion, finding that the plaintiff failed to exhaust administrative remedies and the futility exception did not apply.On appeal, the Supreme Court of Rhode Island affirmed the Superior Court’s judgment. The Court held that the plaintiff was required to exhaust administrative remedies for his as-applied challenges and that the futility exception did not apply because the AAD had independent authority to grant variances. For the facial constitutional challenge, the Court determined that the complaint failed to state a claim upon which relief could be granted. The judgment dismissing the complaint was affirmed and the matter remanded. View "DiBiccari v. State of Rhode Island" on Justia Law

A man using a cane visited a public beach in Rhode Island and slipped and fell in the bathroom, allegedly due to sand and water on the floor. He suffered several injuries, including a fractured hip, and required medical attention. He filed a negligence lawsuit against the state, claiming the state failed to maintain the bathroom safely, failed to warn of the dangerous condition, and failed to clean the facility. After his death from unrelated causes, his daughter, as administrator of his estate, was substituted as plaintiff.The Rhode Island Superior Court reviewed the case following extensive discovery. The state moved for summary judgment, asserting immunity under the Rhode Island Recreational Use Statute (RUS), which shields landowners from liability for injuries on land open to the public for recreational use unless the injury results from willful or malicious failure to guard or warn against a dangerous condition. The plaintiff argued there were factual issues regarding the state’s knowledge and actions, relying on complaints about cleanliness and state policies. The Superior Court found no evidence the state had specific notice of the hazardous condition or prior similar incidents, and ruled that the RUS applied, granting summary judgment for the state. The court did not reach the issue of the public duty doctrine.The Supreme Court of Rhode Island reviewed the grant of summary judgment de novo. The Court held that the plaintiff failed to present evidence showing that the state willfully or maliciously failed to warn against or remedy a known dangerous condition. There was no genuine issue of material fact, and the state was entitled to immunity under the RUS. Accordingly, the Supreme Court of Rhode Island affirmed the Superior Court’s judgment in favor of the state. View "Estate of Campagnone v. The State of Rhode Island" on Justia Law

The plaintiffs purchased undeveloped property in Westerly, Rhode Island, in 1999. In 2007, they applied to the Rhode Island Department of Environmental Management (DEM) for permission to install an onsite wastewater treatment system (OWTS), a prerequisite for building a residence on their land. DEM denied their application because the groundwater table on the property was only five inches below the surface, while regulations required a minimum of twelve inches. The plaintiffs did not pursue an administrative appeal at that time.In 2020, more than a decade after the denial, the plaintiffs filed suit in Washington County Superior Court, seeking declaratory relief and compensation for an alleged regulatory taking under state and federal law. They also asserted that the regulation violated their rights to equal protection and due process. The state moved to dismiss the action, contending it was time-barred, the plaintiffs failed to exhaust administrative remedies, and they lacked standing. The Superior Court agreed, holding that the claims were barred by the statute of limitations, that administrative remedies had not been exhausted, and that the plaintiffs lacked standing. The court dismissed the case with prejudice.On appeal, the Supreme Court of Rhode Island reviewed whether the lower court’s dismissal was proper. The Court held that the three-year statute of limitations applied to all claims, and the continuing violation doctrine did not toll the limitations period because DEM’s denial of the permit was a discrete act, not a continuing violation. The Court further found the plaintiffs lacked standing for prospective relief because they did not allege an actual or imminent injury, as any future application might not necessarily be denied. The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. View "Majeika v. State of Rhode Island" on Justia Law

Several charitable trusts were established between 1930 and 1969, each naming Memorial Hospital in Pawtucket, Rhode Island, as a beneficiary. The trusts specified the use of funds for purposes such as maintaining “free beds” or supporting general hospital operations. Memorial Hospital operated as an acute care hospital until financial difficulties led to its closure in 2018, at which point it ceased providing inpatient and emergency services. Some outpatient services continued on the campus, but Memorial Hospital was no longer a functioning hospital. Bank of America, as trustee, sought judicial guidance under the cy près doctrine to designate new beneficiaries for the trusts whose purposes could no longer be fulfilled due to the hospital’s closure.Upon review, the Providence County Superior Court found that the closure of Memorial Hospital rendered the trusts’ original purposes impossible, and that each settlor evidenced a general charitable intent. The court conducted a bench trial, considering expert testimony, historical context, and proposals from various organizations, including Kent County Hospital, The Miriam Hospital Foundation, and Progreso Latino. The trustee and several parties proposed a split between The Miriam Hospital Foundation and Progreso Latino, while others argued for Kent County Hospital as the successor beneficiary. The court ultimately rejected both proposals, finding that neither alternative met the settlors’ intent to support actual hospital care.The Supreme Court of Rhode Island reviewed the case on appeal. The Court affirmed the Superior Court’s judgment, holding that the cy près doctrine applied and that The Miriam Hospital, as an acute care hospital offering inpatient and emergency services, was the closest alternative beneficiary to fulfill the original charitable purposes. The Court clarified that the trust proceeds must be used by Miriam Hospital for inpatient and emergency care, consistent with the settlors’ intent. The judgment of the Superior Court was affirmed. View "Bank of America, N.A. v. Neronha" on Justia Law