Justia Rhode Island Supreme Court Opinion Summaries

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

Police investigating suspected drug trafficking received information from a confidential informant about two individuals selling drugs. Surveillance linked the suspects to multiple addresses. The investigation included controlled drug buys and installation of a pole camera outside an apartment building. On April 4, 2023, the informant reported a possible deceased person inside one of the apartments. Surveillance footage showed the suspects and another individual entering and exiting the building. Police detained the suspects at a traffic stop and seized keys. Officers then entered the apartment building without a warrant, finding a deceased person in the second-floor apartment and, upon entering the third-floor apartment, discovering drug paraphernalia and contraband.The Providence County Superior Court held a hearing on the defendant’s motion to suppress evidence obtained during the warrantless search and seizure. The trial justice denied the motion, concluding that the police were responding to a sudden emergency involving a possible death and acted rationally to protect citizens from harm and prevent destruction of property. The defendant was subsequently found guilty on all charges following a bench trial and sentenced to twenty-five years, with twenty years to serve and five years suspended. The defendant appealed.The Supreme Court of Rhode Island reviewed the denial of the motion to suppress under the Fourth Amendment and article 1, section 6 of the Rhode Island Constitution, applying the totality of the circumstances standard and deferring to factual findings unless clearly erroneous. The Court held that police had no constitutionally permissible reason to enter the third-floor apartment after finding the deceased in the second-floor apartment and that the exigency justifying entry had evaporated. The Court concluded that the error was not harmless, vacated the conviction, and remanded for a new trial. View "State v. Moronta" on Justia Law

Two neighboring property owners became embroiled in a dispute when the plaintiffs, who reside at 141 Post Road in Warwick, Rhode Island, began experiencing persistent and disruptive noises from the adjacent property at 175 Post Road, owned by the defendants. The plaintiffs moved into their home in 2021 without incident, but beginning in July 2024, they reported loud construction-related noises including hammering, vehicle alarms, and machinery, linked first to activities by JOGO Corporation, a tenant of a crane company on the defendants’ property, and later to other similar operations. The plaintiffs and their witnesses described the sounds as intolerable and detrimental to their use and enjoyment of their home, affecting their emotional well-being and daily activities. Additionally, plaintiffs complained of intrusive conduct, including filming or photographing by the defendants.The plaintiffs filed a complaint in the Rhode Island Superior Court in October 2024, seeking damages and injunctive relief for private nuisance. After a multi-day evidentiary hearing with testimony from neighbors, police officers, and the parties, the Superior Court judge found that the plaintiffs had established a likelihood of success on their nuisance claim, irreparable harm, that the balance of equities favored the plaintiffs, and that injunctive relief would preserve the status quo. The court issued a preliminary injunction prohibiting the defendants from harassing, filming, or interfering with the plaintiffs' enjoyment of their property and from conducting activities that violated the city’s noise ordinance or unreasonably interfered with the plaintiffs’ use of their home.On appeal, the Supreme Court of Rhode Island affirmed the Superior Court’s order. The Supreme Court held that the lower court did not abuse its discretion in granting the preliminary injunction, finding that the requirements for such relief—including likelihood of success, irreparable harm, balancing of equities, and preservation of the status quo—were properly considered and satisfied. The Court also held that objections to the specificity of the order were waived. View "Carlton v. Avagyan" on Justia Law

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