Justia Rhode Island Supreme Court Opinion Summaries

The case centers on a dispute between an insurer and its insureds regarding coverage for alleged vandalism at a rental property. Brenda Ricci purchased the property at a foreclosure sale, obtained an insurance policy from Rhode Island Joint Reinsurance Association (RIJRA), and allowed the previous owner, David Christian, to remain as a tenant. After a rent dispute and condemnation of the property for code violations, the tenant vacated. The Riccis discovered damage, claimed it was vandalism, and submitted an insurance claim. RIJRA investigated, concluded the damage was unfinished remodeling rather than vandalism, and reserved its defenses.RIJRA filed a declaratory judgment action in the Washington County Superior Court seeking clarification of its obligations under the policy. The Riccis counterclaimed, seeking appraisal and asserting various claims. RIJRA later amended its complaint to add fraud and misrepresentation counts. The Superior Court bifurcated proceedings and stayed the counterclaims. A jury trial was held, during which the Riccis’ motions to exclude evidence and send the matter to appraisal were denied. The jury found the Riccis had not proven the alleged damage occurred during the policy period, resulting in a verdict for RIJRA. Judgment was entered in favor of RIJRA on the main claim and on all counterclaims. The Riccis’ motions for a new trial were denied.On appeal to the Supreme Court of Rhode Island, the Riccis challenged evidentiary rulings, jury instructions, denial of appraisal, admission of deposition testimony, and denial of their new trial motions. The Supreme Court affirmed the Superior Court’s judgment and its denial of the new trial motions, holding that the trial justice did not abuse her discretion or commit reversible error in any of the challenged rulings, and that the Riccis failed to prove their claim was covered under the policy. View "Rhode Island Joint Reinsurance Association v. Ricci" on Justia Law

The plaintiff was injured while riding a public bus operated by the Rhode Island Public Transit Authority (RIPTA) after the bus driver braked abruptly when a car cut in front of the bus. The plaintiff alleged the driver acted negligently, causing her injuries, and sought damages for medical expenses and pain and suffering. The incident occurred on May 29, 2016. The plaintiff testified that the driver was distracted and speeding, while the driver stated he was operating safely and only stopped suddenly to avoid a collision after being cut off by another vehicle. The plaintiff did not immediately seek medical attention but visited the emergency room days later, where she was diagnosed with a shoulder fracture and chest contusions. RIPTA contested liability and argued that the plaintiff had preexisting conditions.The Rhode Island Superior Court conducted a jury trial, during which the court made several evidentiary rulings, allowed RIPTA to amend its answer to assert the sudden emergency doctrine, and dismissed a juror who had scheduling conflicts. The court also issued jury instructions on spoliation after it was revealed that bus video footage was not preserved. The jury returned a verdict for RIPTA. The plaintiff subsequently filed a motion for a new trial, which the Superior Court denied after addressing both procedural and substantive arguments.Upon review, the Supreme Court of Rhode Island affirmed the Superior Court’s judgment. The Supreme Court held that the evidentiary rulings were not an abuse of discretion, the spoliation instruction was proper, and the amendment of RIPTA’s answer and the jury instructions were permissible. The Court found that the plaintiff had waived or failed to preserve several arguments and that no reversible error occurred regarding the dismissal of the juror or the denial of the motion for a new trial. View "Galindez v. Rhode Island Public Transit Authority" on Justia Law

An employee of a corporation died following a motor vehicle accident that occurred while he was acting within the course of his employment. His widow, acting individually and on behalf of his estate and their children, collected funds from her personal auto policy, the tortfeasor’s policies, and the tortfeasor directly. She then sought underinsured motorist (UIM) benefits under her late husband’s employer’s commercial auto policy, issued by an insurer, which covered a fleet of twenty-six vehicles and listed the employer, a corporation, as the Named Insured. The insurer paid $1,000,000, the per-accident UIM limit, but denied the widow’s further claim to “stack” the UIM limits for each covered vehicle, totaling $26,000,000, on the basis that stacking was only available to an “individual Named Insured.”The widow filed suit in Kent County Superior Court, seeking a declaratory judgment and alleging breach of contract and bad faith. The insurer moved for summary judgment, and the widow filed a cross-motion. The Superior Court found that there was no circumstance in which the decedent could be considered an “individual Named Insured” under the policy, granted summary judgment to the insurer, and denied the widow’s cross-motion. Final judgment entered, and the widow appealed.The Supreme Court of Rhode Island reviewed the grant of summary judgment de novo. It held that the policy unambiguously allowed stacking only for an individual Named Insured, which the decedent was not. The Court found that the insurer did not waive its defenses, the stacking benefit was not illusory, and the “Martinelli exception” did not apply. The Court also concluded that the Rhode Island statutory stacking provision for UIM coverage does not apply to employees under a commercial fleet policy where the corporation is the Named Insured. The judgment of the Superior Court was affirmed. View "Horsman v. Travelers Property Casualty Company of America" on Justia Law

Two individuals died in a 2012 plane crash involving a Piper PA-32-300 Cherokee 6 aircraft powered by a Lycoming engine manufactured by Avco Corporation in the early 1970s. The engine had undergone overhauls in 1983 and 2004, with several component parts serviced or replaced during those processes. The estates and families of the decedents brought suit in Rhode Island Superior Court against Avco, alleging strict liability, negligence, breach of warranty, and negligent infliction of emotional distress. Avco asserted a defense under the General Aviation Revitalization Act of 1994 (GARA), which bars certain claims against aircraft manufacturers after eighteen years, subject to specific exceptions for misrepresentation and newly installed parts.The Providence County Superior Court addressed the applicability of GARA’s exceptions. The court found that the plaintiffs’ amended complaint failed to plead, with the required specificity, facts showing that Avco knowingly misrepresented or withheld information from the FAA as required by GARA’s misrepresentation exception. As a result, discovery on this theory was limited. On the rolling provision, the court allowed discovery on specific parts allegedly replaced within eighteen years prior to the crash but found plaintiffs failed to prove that any such part was both manufactured by Avco and causally related to the accident. The trial justice granted summary judgment for Avco on all claims.The Supreme Court of Rhode Island reviewed the lower court’s grant of summary judgment de novo. The court held that GARA requires plaintiffs to plead specific facts to invoke the misrepresentation exception, which the plaintiffs had not done. The court also held that the plaintiffs failed to prove the application of GARA’s rolling provision, as they did not establish that any newly installed part made by Avco caused the crash. The Supreme Court affirmed the Superior Court’s judgment in favor of Avco. View "Williams v. Avco Corporation" on Justia Law

A restaurant owner applied for a liquor license for a property in Providence, Rhode Island. Nearby property owners, including the appellant, filed an objection to the license under a state law that allows such objections to bar issuance of liquor licenses within 200 feet of their property. After the local licensing board could not issue the license due to this objection, the restaurant owner lobbied the General Assembly, which enacted a special law allowing the Providence Board of Licenses to exempt this specific address from the objection rule. This exemption applied only to the property at 225 Waterman Street and was enacted without a vote by local Providence voters.After the special law was passed, the restaurant owner reapplied, and the Board granted the license over objections. The appellant appealed to the Rhode Island Department of Business Regulation (DBR), which stayed the license but did not rule on the constitutional issue. The appellant then filed suit in the Rhode Island Superior Court, arguing that the special exemption was unconstitutional because Article 13, Section 4 of the Rhode Island Constitution requires local voter approval for legislation relating specifically to the property, affairs, or government of a particular city or town. The Superior Court granted summary judgment for the defendants, holding that liquor licensing is a matter of statewide concern and does not require local voter approval.On appeal, the Supreme Court of Rhode Island reviewed the constitutionality of the special law. The court held that the legislation, which singled out a specific property in Providence for exemption from a generally applicable law, related to the property, affairs, and government of a particular city. Because the law did not receive local voter approval as required by Article 13, Section 4, it was void. The Supreme Court vacated the judgment of the Superior Court and remanded for entry of judgment in favor of the appellant. View "Myles Standish Associates, LP v. The City of Providence" on Justia Law

The parties married in October 2018 and separated in May 2021, with the plaintiff filing for divorce soon after. The central issue in their divorce proceedings was the distribution of marital assets, especially stock options and restricted stock units (RSUs) earned by the defendant through her employment at Moderna. The plaintiff asserted he played a significant role in managing the couple’s finances and the defendant’s stock transactions, while the defendant testified about the breakdown of their marriage and the nature of her employment compensation. Key factual disputes included the timing and manner of division of the stock options and RSUs and the handling of transfers between the defendant’s brokerage and checking accounts.The case was initially tried before a general magistrate of the Family Court, who heard testimony from both parties and a certified divorce financial analyst. The magistrate found the defendant’s testimony credible and determined the plaintiff was solely at fault for the breakdown of the marriage. The magistrate awarded the defendant the entirety of her checking account and 100% of unvested stock options and RSUs as of the separation date, while dividing vested options and RSUs as of that same date. The plaintiff’s appeal was denied by a justice of the Family Court, who affirmed the magistrate’s decision.The Supreme Court of Rhode Island reviewed whether the Family Court erred in valuing marital assets as of the date of separation rather than the date of divorce and in not dividing unvested stock options and RSUs. The Court held that compelling circumstances justified valuation as of the separation date, given the short marriage duration and the defendant’s ongoing employment. It further determined the magistrate acted within his discretion in awarding unvested compensation solely to the defendant. The Court affirmed the Family Court’s order. View "Hogan v. Wong" on Justia Law

A married couple, after more than two decades together and raising two children, underwent a contentious divorce. The wife filed for divorce citing irreconcilable differences, and the husband responded with a counterclaim on similar grounds. During the proceedings, the parties reached a marital settlement agreement that resolved most issues but left unresolved whether certain foreign assets inherited or gifted to the wife were part of the marital estate, and whether the wife was entitled to attorneys’ fees due to the husband’s conduct during litigation.After a trial in the Providence County Family Court, a magistrate determined that the foreign assets were nonmarital property, as there was no evidence they had been transmuted into marital assets. The magistrate found these assets remained segregated, had not been maintained with marital funds, and the husband’s contributions toward them were minimal and gratuitous. On the issue of attorneys’ fees, the magistrate concluded that the husband had prolonged litigation with repeated, meritless arguments and filings, violating both Rule 11 of the Family Court Rules of Domestic Relations Procedure and Rhode Island General Laws § 9-29-21. As a result, the wife was awarded $74,680 in attorneys’ fees. The magistrate also addressed the division of the 2022 tax refund and health insurance costs, ordering an equal split of the tax return and insurance premiums, despite the inclusion of adult children on the policy.The husband appealed the magistrate’s rulings to a justice of the Family Court, who upheld both the classification of assets and the attorneys’ fees award, finding no abuse of discretion or error in law. The Rhode Island Supreme Court reviewed the matter and affirmed the Family Court’s decision in all respects, holding that the foreign assets remained nonmarital, the equal division of the tax return and health insurance costs was proper, and the attorneys’ fees award was appropriate based on the husband’s conduct. The case was remanded for further proceedings consistent with the opinion. View "Constantino v. Orban" on Justia Law

Two men, Jamal Cruz and Rokiem Henley, attended a nightclub in Providence with friends. After the club closed, Cruz had a brief verbal disagreement with two other men, including Terrel Barros and Stephen Bodden. As Cruz and Henley were leaving, Bodden confronted Cruz outside, followed by gunshots that injured Henley and fatally wounded Cruz. Police officers nearby responded quickly, saw Bodden and Barros get into a car, and arrested both men. Barros was subsequently charged and convicted of first-degree murder and several related offenses, largely based on Cruz’s dying identification, eyewitness testimony, and evidence presented at trial.Following his conviction, Barros filed an application for postconviction relief in the Rhode Island Superior Court, alleging several constitutional violations, actual innocence, and the existence of newly discovered evidence. During the postconviction hearing, Barros introduced testimony from Gloria Parajon, Bodden’s cousin, who stated that Bodden had privately confessed to her, on multiple occasions, that he was the shooter. The hearing justice found Parajon’s testimony to be newly discovered, credible, and not merely cumulative, and concluded it could change the verdict at a new trial. The Superior Court granted Barros’s application for postconviction relief and vacated his conviction.On review, the Supreme Court of Rhode Island determined that the Superior Court did not err in admitting Parajon’s testimony as a statement against penal interest under Rule 804(b)(3) of the Rhode Island Rules of Evidence, and that her statements were sufficiently corroborated. The Supreme Court affirmed the judgment of the Superior Court, holding that Barros was entitled to postconviction relief based on newly discovered evidence, and remanded the case for further proceedings. View "Barros v. State of Rhode Island" on Justia Law

On May 14, 2021, several siblings and friends gathered at a residence in Providence, Rhode Island, using a Nissan Murano to run errands and socialize. Later that evening, they met Tyreik Grundy, who arrived in a Honda Civic. Both cars parked in a lot across from the residence. While the group was in and around the Murano, two individuals approached, and one fired several shots into the vehicle, killing Grundy. The shooter was described as wearing a red hoodie and gloves, and DNA evidence from a smudge on the Murano’s rear passenger window was later linked to the defendant. Surveillance footage and cell phone data were used to tie a white Infiniti, allegedly associated with the defendant, to the scene.The Providence County Superior Court jury convicted the defendant of first-degree murder, conspiracy to commit assault with a dangerous weapon, discharging a firearm during a crime of violence resulting in death, and carrying a pistol without a license. After the verdict, the defendant filed a motion for a new trial, arguing the evidence was insufficient to establish he was the shooter and that the jury misapplied the law. The trial justice denied the motion, finding the circumstantial evidence—car, cell phone, and DNA—supported the verdict and that reasonable minds could differ about the defendant’s culpability.On appeal, the Supreme Court of Rhode Island reviewed the denial of the motion for a new trial. The Court concluded that the trial justice had not sufficiently articulated her reasoning as the “thirteenth juror,” specifically failing to explain how she weighed the evidence and whether she agreed with the jury’s verdict. As a result, the Supreme Court vacated the denial of the motion for a new trial and remanded the case to the Superior Court for a new hearing on the motion. View "State v. Page" on Justia Law

On August 12, 2014, Eva Pena was injured while attempting to board a Rhode Island Public Transit Authority (RIPTA) bus in Providence. She alleged that the bus driver closed the doors on her, causing her to fall and sustain serious injuries. After her death in 2019, her estate continued the suit, claiming negligence by RIPTA. At trial, testimony was presented from multiple witnesses, including Pena’s deposition, the bus driver, a RIPTA supervisor, and Pena’s son. Central to the dispute was the supervisor’s account of a conversation with Pena, which had been facilitated by an unidentified Spanish interpreter at the scene.The Providence County Superior Court admitted the supervisor’s testimony and report about what Pena allegedly said through the interpreter, overruling objections that this constituted inadmissible hearsay. The jury returned a verdict for RIPTA, finding that the plaintiff had not proven negligence. The plaintiff moved for a new trial, arguing that the trial justice erred in allowing hearsay testimony via the unidentified interpreter. The trial court denied the motion, finding the issue unsettled under Rhode Island law and suitable for appellate clarification.The Supreme Court of Rhode Island reviewed the case and reversed the Superior Court’s denial of a new trial. The Supreme Court held that admitting the supervisor’s testimony and report regarding Pena’s statements, relayed through the unidentified interpreter, was an abuse of discretion because it constituted inadmissible hearsay lacking reliability and trustworthiness. The Court found that this evidence was not cumulative and its admission affected the substantial rights of the parties. The case was remanded for a new trial consistent with the Supreme Court’s opinion. View "Fernandez v. Rhode Island Public Transit Authority" on Justia Law