Justia Rhode Island Supreme Court Opinion Summaries

The case centers on the fatal shooting of a seventeen-year-old during a street altercation in Providence, Rhode Island. The defendant was accused of firing a gun at the victim as she approached a fight between her sister and the defendant’s sister. Witnesses saw the defendant shoot in the victim’s direction, after which she collapsed and later died at the hospital. The defendant was apprehended and charged with second-degree murder and two firearms offenses.At the initial trial in the Rhode Island Superior Court, the prosecution exercised a peremptory strike against the only African-American prospective juror. The trial court allowed the strike, accepting the prosecutor’s asserted concern about potential workplace repercussions for the juror. The jury, which had no African-American members, convicted the defendant on the main charges. On appeal, the Rhode Island Supreme Court upheld the conviction, finding the peremptory strike was based on race-neutral grounds. After a habeas petition was denied by the federal district court, the United States Court of Appeals for the First Circuit reversed, holding that the strike was not race-neutral and ordered the state courts to vacate the conviction unless a new trial was held.At the retrial, again only one African-American venireperson was present. The prosecution sought to remove this juror for cause and, when that was denied, exercised a peremptory challenge, citing the juror’s pending criminal cases and lack of candor. The trial justice ultimately allowed the peremptory challenge, and a jury again lacking African-Americans convicted the defendant. The defendant’s motion for a new trial was denied.On appeal, the Supreme Court of Rhode Island held that the trial court failed to properly conduct the third step of the Batson analysis, which requires a probing inquiry into whether the prosecutor’s race-neutral explanation was genuine or pretextual. The court concluded this failure constituted structural error and vacated the conviction, remanding the case for a new trial. View "State v. Porter" on Justia Law

A married couple divorced in 2010 and entered into a Property Settlement Agreement (PSA), which provided that the husband would transfer one-half of his fully vested retirement plan through his employer or union to the wife by way of a Qualified Domestic Relations Order (QDRO). The retirement plan consisted of both an annuity and a pension. At the time of divorce, a QDRO was entered to divide the annuity, but not the pension. The husband began receiving pension benefits in June 2015, but did not pay the wife any share. In December 2023, the wife filed a motion in Family Court to reopen the divorce and to enter a QDRO dividing the pension.The general magistrate in the Rhode Island Family Court found the wife’s action timely under the ten-year statute of limitations, holding that her cause of action accrued when the husband began receiving pension benefits and failed to pay her share. The magistrate found the PSA unambiguous, requiring equal division of the retirement plan, and ordered entry of a QDRO for the pension, payment of past-due amounts, and ongoing payments. The husband appealed to the Chief Judge of the Family Court, who affirmed the magistrate's decision, agreeing that the statute of limitations began running at the time of the breach in 2015.On further appeal, the Supreme Court of Rhode Island affirmed the Family Court's order. The Supreme Court held that the PSA was unambiguous in requiring equal division of the retirement plan, including both the annuity and the pension. The Court held that the statute of limitations began when the husband first received pension payments and failed to pay the wife her share, making her motion timely. The Court further held that ordering a QDRO for the pension did not reform or modify the PSA, but simply enforced its terms. View "Codere-Wilson v. Wilson" on Justia Law

A general contractor hired a subcontractor to perform electrical work on a marina expansion project in Bristol, Rhode Island. The subcontract specified that time was critical and required timely written notice of delays, as well as an indemnification clause. After the parties negotiated an expanded scope of work and the general contractor paid a deposit, the subcontractor failed to meet the estimated completion schedule and did not provide required delay notices. As a result, the town threatened to terminate the general contract. The general contractor then terminated the subcontract and hired a replacement. The contractor sued the subcontractor and its CEO in Providence County Superior Court, alleging breach of contract, negligent misrepresentation, fraud, and conversion, and sought damages and attorney’s fees.The defendants answered and asserted affirmative defenses. After repeated failures to comply with discovery orders and to retain new counsel following their attorney’s withdrawal, the Superior Court issued conditional orders of default, giving the defendants multiple opportunities to comply. When they did not, the court entered a default judgment for the contractor, including damages, costs, prejudgment interest, and attorney’s fees. The CEO appeared at some hearings but not others, raising concerns about notice and service, which were addressed by the trial justice, who instructed him to file a Rule 60 motion to vacate the default if he wished to contest notice. No such motion was filed. Both sides subsequently filed motions with the Rhode Island Supreme Court relating to remand and post-judgment relief.The Supreme Court of Rhode Island reviewed whether the trial justice abused discretion in entering the default judgment. It held that the defendants’ failure to file a Rule 60 motion or properly raise notice issues in the lower court precluded appellate review of those issues. The Court found no abuse of discretion in the entry of default and affirmed the Superior Court’s judgment. The imposition of a cash bond as a condition for remand did not violate due process. View "Reagan Marine Construction, LLC v. Costa" on Justia Law

On the morning of September 25, 2021, Julio Castro saw Jorge Garcia, an acquaintance, at Roque’s Café in Providence, Rhode Island. Garcia was accompanied by his employer, Arturo Walker. Prior to this encounter, Juan Rivera, a friend of Castro, had inquired about Garcia, expressing an interest in discussing drugs with him. After a brief exchange at the café, Garcia was fatally shot by an individual captured on surveillance footage wearing a black sweatshirt with white lettering. Police determined the shooter arrived at the scene with another person in a red Toyota with a black hood and linked a black Dodge Ram at the scene to Rivera. Further investigation, including witness testimony and video evidence, implicated Rivera, who was later charged with multiple offenses including first-degree murder.After the incident, the Providence County Superior Court conducted a jury trial. The state introduced surveillance footage and other evidence, including statements from a now-deceased individual, Josue Calderon, and testimony from Isamarys Segura. Rivera’s defense objected to the admission of certain surveillance videos, argued hearsay exceptions were improperly applied to Calderon's statements, and challenged the admissibility of testimony about “the word on the streets.” The jury found Rivera guilty on all counts, and he was sentenced to two consecutive life terms plus additional concurrent sentences for the other offenses.The Supreme Court of Rhode Island reviewed the convictions. The court held that the trial justice did not abuse her discretion in admitting the surveillance footage, finding the foundation for authenticity under Rule 901 was sufficiently established through expert testimony. The court also determined that the defense failed to preserve objections to Calderon's statements and Segura’s testimony for appellate review, as contemporaneous objections were not made at trial. Accordingly, the court affirmed the Superior Court’s judgment. View "State v. Rivera" on Justia Law

Two plaintiffs, both incarcerated at the Adult Correctional Institutions in Rhode Island, alleged that the Department of Corrections failed to properly treat their preexisting ankle injuries. They claimed the Department denied them necessary accommodations, including access to elevators and elevation pillows, resulting in painful daily traversal of stairs and inadequate medical care. The plaintiffs filed a complaint citing various federal and state legal provisions, with one count specifically alleging disability discrimination under the Rhode Island Civil Rights Act (RICRA).The United States District Court for the District of Rhode Island denied the Department’s motion for summary judgment on the RICRA claim. The court found genuine disputes of material fact and reasoned that Rhode Island’s State Tort Claims Act (STCA) broadly waived sovereign immunity for “all actions of tort.” The District Court concluded that actions under RICRA sound in tort, meaning the state’s immunity was waived. The Department appealed, and the United States Court of Appeals for the First Circuit certified to the Rhode Island Supreme Court the question of whether RICRA discrimination claims are “actions of tort” under the STCA.The Rhode Island Supreme Court, reviewing the certified question de novo, determined that discrimination claims brought under RICRA are indeed “actions of tort” within the meaning of the STCA. The Court based its holding on the broad definition of tort in Rhode Island law and federal precedent, reasoning that RICRA creates a legal duty and provides remedies for violation of that duty, consistent with tort law. Therefore, claims under RICRA fall within the STCA’s waiver of sovereign immunity, and the certified question was answered in the affirmative. The Court ordered the papers returned to the First Circuit for further proceedings. View "Parente v. Lefebvre" on Justia Law

A carpenter who managed his own construction business was involved in a multi-vehicle accident in September 2013, while driving a car owned by another individual. The accident, caused by another driver, resulted in significant injuries and financial losses for the plaintiff, who claimed over $75,000 in medical expenses and more than $250,000 in lost income. The plaintiff had a business insurance policy with Main Street America Assurance Company (MSAA) during the relevant period. The driver and owner of the vehicle that struck the plaintiff were insured by GEICO General Insurance Company.Previously, the plaintiff sued the at-fault driver and owner (the Mathieus) in Kent County Superior Court and later settled that case. In the present suit, the plaintiff brought claims against both GEICO and MSAA for breach of contract, breach of the implied covenant of good faith and fair dealing, and statutory bad faith refusal to settle. Both defendants moved to sever the bad faith and implied covenant claims and to stay discovery on those claims, which the Superior Court granted. The court also denied the plaintiff’s motion to compel additional document production from GEICO, pending resolution of summary judgment motions. Ultimately, the Superior Court granted summary judgment for both defendants.On appeal, the Supreme Court of Rhode Island affirmed the Superior Court’s judgments. The Court held that MSAA’s business insurance policy expressly excluded coverage for injuries arising from automobile use, so the plaintiff’s contract and related claims failed as a matter of law. As to GEICO, the Court found that Rhode Island law prohibits direct actions against an insurer under these circumstances, and the plaintiff had no contractual or third-party rights under the GEICO policy. The Court also concluded that the issues related to severance and discovery were moot given the disposition of the contract claims. View "Menge v. GEICO General Insurance Company" on Justia Law

A married couple separated in 2012, with the husband moving out of the marital home and into another state. In February 2020, the wife filed for divorce in Rhode Island on the grounds of living separate and apart for over three years. Neither party was represented by counsel, and the husband did not file an answer or counterclaim. Both appeared remotely for a nominal divorce hearing in June 2020, where the court found the marriage irretrievably broken, the parties self-sufficient, and no joint property or debts to divide. A Decision Pending Entry of Final Judgment (DPEFJ) and a final judgment were both entered on October 8, 2020. After the divorce, the wife purchased a lottery ticket and won $4 million.The husband subsequently moved to vacate the final judgment in the Providence County Family Court, arguing that the lottery ticket was purchased before the divorce was final, making it a marital asset. He also claimed procedural defects, specifically that the final judgment and DPEFJ were entered simultaneously, violating the statutory requirement of a 20-day waiting period. The general magistrate found the judgment was entered prematurely but not void, yet granted relief due to procedural irregularities and continued the matter to address potential distribution of the lottery winnings. The wife appealed, arguing that the magistrate exceeded his authority and that any error was at most procedural.The Supreme Court of Rhode Island reviewed whether the divorce judgment was void and subject to vacatur. The Court held that the Family Court had subject-matter jurisdiction and that the simultaneous entry of the DPEFJ and final judgment was a procedural error, not a jurisdictional defect. The Court further found no due process violation or prejudice to the husband and concluded the lottery winnings were not marital property. The Supreme Court affirmed the Family Court’s denial of the motion to vacate the final judgment. View "Varela v. Monteiro" on Justia Law

The defendant was indicted for first-degree sexual assault following an incident in March 2021. The complainant testified that she was invited to a social gathering by the defendant, consumed alcohol throughout the night, and later awoke in an unfamiliar motel room unable to move, where she observed the defendant engaging in sexual acts against her will. The complainant denied consenting to sexual activity or going to the motel. A motel employee corroborated that the complainant appeared intoxicated, and forensic testing on her clothing and swabs revealed DNA consistent with the defendant. The defendant conceded to sexual intercourse but claimed it was consensual.The case was tried before the Kent County Superior Court, where a jury heard testimony from the complainant, witnesses, and forensic experts. The laboratory supervisor who reviewed and approved the DNA analysis, but did not perform the testing herself, testified regarding the DNA findings. The defendant moved to strike her testimony, arguing it violated his right to confront the analyst who performed the testing, relying on Supreme Court precedents. The trial justice denied the motion, referencing prior Rhode Island Supreme Court decisions permitting supervisory analysts to testify.On appeal, the Supreme Court of Rhode Island reviewed whether the defendant properly preserved his Confrontation Clause objection and whether an intervening Supreme Court decision, Smith v. Arizona, warranted a departure from the raise-or-waive rule. The Court held that the defendant’s objection was not based on a novel rule of law and was untimely, as prior precedent already addressed the issue. The Court concluded that the intervening decision did not alter existing controlling law and affirmed the Superior Court’s judgment of conviction. View "State v. Vasquez" on Justia Law

The plaintiff, an employee of Verizon, was involved in a motor vehicle accident while driving a company-assigned bucket truck during work hours. He typically drove his personal vehicle to work, then operated the Verizon truck exclusively for his work assignments, including commuting between the central work location and job sites. The Verizon truck was not for personal use, but was used daily for work, and the plaintiff kept work-related items in it. After the accident, the plaintiff sought uninsured motorist benefits under his personal auto insurance policy with the defendant, Nationwide, but his claim was denied under the policy's exclusion for injuries suffered while occupying a vehicle furnished for his “regular use.”The plaintiff filed suit in Providence County Superior Court, seeking a declaratory judgment that he was entitled to coverage. The defendant moved for summary judgment, arguing the facts were undisputed and the regular use exclusion applied. The hearing justice denied the motion, finding factual questions remained about whether the Verizon truck was furnished for the plaintiff’s regular use. At trial, after both parties stipulated to undisputed facts and the plaintiff rested, the defendant moved to discharge the jury, arguing that only a question of contract interpretation remained. The trial justice agreed, discharged the jury, and indicated that the regular use question was legal, not factual.The Supreme Court of Rhode Island granted review and held that, under its prior decision in Ricci v. United States Fidelity and Guaranty Company, whether a “non-owned” vehicle is furnished for “regular use” within the meaning of an insurance policy is a question of fact for the jury. The Court concluded that the trial justice erred by removing the question from the jury and quashed the Superior Court’s order, remanding the case for a new trial. View "O'Rourke v. Nationwide Mutual Insurance Company" on Justia Law

A nonprofit healthcare organization, which operates numerous facilities in Providence and one property in Warwick, acquired the Warwick property in 2020. The Warwick site is used primarily for administrative functions and virtual patient services. The organization treats a large number of low-income patients, but not exclusively, as some patients may have higher incomes. In 2021, the Rhode Island General Assembly enacted a statute that exempts from property tax “real and tangible personal property of [the nonprofit], a Rhode Island domestic nonprofit corporation, located in Providence, Rhode Island.” The organization applied to the Warwick tax assessor for an exemption based on this statute and an alternate general exemption for entities serving the poor. The Warwick tax assessor denied the request, concluding the statutory exemption applied only to properties in Providence.The organization appealed to the Warwick Tax Board of Review, which also denied the exemption. It then filed an appeal in the Kent County Superior Court, asserting both the specific and general exemptions applied to its Warwick property. The Superior Court granted summary judgment for the tax assessor, finding the statutes unambiguous and holding the property was not exempt because it was not located in Providence, and because the organization did not exclusively serve the poor.On appeal, the Supreme Court of Rhode Island reviewed the summary judgment de novo. The Court held that the specific statutory exemption only applies to properties owned by the nonprofit in Providence, not Warwick. Additionally, the general exemption for entities aiding the poor requires exclusive service to the poor, which the nonprofit does not meet. The Court affirmed the Superior Court’s judgment, ruling the Warwick property is not exempt from taxation under either statute. View "The Providence Community Health Centers, Inc. v. Dupuis" on Justia Law