Justia Rhode Island Supreme Court Opinion Summaries

Sharon and Kieran Cunningham were married in 1994 and divorced in 2021. They entered into a marital settlement agreement (MSA) that was incorporated but not merged into the final divorce decree. The MSA included provisions about the use and sale of their home in Middletown, Rhode Island, which were modified twice by mutual agreement. In January 2024, Kieran's counsel offered to purchase the home, leading to a dispute over whether the Family Court could modify the MSA to allow an appraisal of the property.Kieran filed a motion in the Family Court to have the home appraised, which Sharon opposed, arguing that the MSA did not provide for such an appraisal. Kieran amended his motion to request an inspection and appraisal, citing Rule 34 of the Family Court Rules of Domestic Relations Procedure. The Family Court held a hearing and ultimately ruled that Kieran had no right to purchase the property under the MSA and sanctioned him for filing an improper motion, awarding Sharon $6,125 in attorneys' fees.The Rhode Island Supreme Court reviewed the case and affirmed the Family Court's decision. The Court held that Kieran's motion was not well-grounded in fact or law and that he sought relief not permitted by the MSA. The Court found that the Family Court did not abuse its discretion in awarding attorneys' fees, as the fees were reasonable and supported by an affidavit from a Rhode Island Bar member. The Supreme Court concluded that the sanctions and attorneys' fees were appropriate given the circumstances. View "Cunningham v. Cunningham" on Justia Law

The defendant and the victim were involved in a fatal shooting that occurred outside the home of the defendant’s former partner, with whom he shared a child. After the end of their romantic relationship, the former partner began seeing the victim. On the night in question, the victim arrived at the former partner’s house, and after an encounter between the defendant and his former partner, the defendant fired multiple gunshots into the victim’s car, resulting in the victim’s death. The defendant was subsequently indicted on multiple charges, including murder and several related offenses. Additional charges were brought based on the defendant’s conduct while incarcerated awaiting trial. The two cases were consolidated and tried together.In the Providence County Superior Court, the defendant was tried before a jury. The trial justice included an instruction on voluntary manslaughter over the state’s objection, but instructed the jury to consider voluntary manslaughter only if it found the state had not proven first- or second-degree murder beyond a reasonable doubt. The defendant objected, arguing that the jury should be allowed to consider whether adequate provocation negated malice even if the elements of murder were otherwise satisfied, and that the state should be required to disprove provocation beyond a reasonable doubt. The jury found the defendant guilty of second-degree murder and several other charges, and not guilty on others. The defendant was sentenced accordingly and appealed.The Supreme Court of Rhode Island reviewed the case. The court held that the trial justice’s instructions were proper, finding that the instructions, when viewed in their entirety, adequately explained the law and did not mislead the jury. The court concluded that the state’s burden of proof was not improperly shifted to the defendant and that the instructions did not violate due process. The judgments of conviction were affirmed. View "State v. Mangru" on Justia Law

E.H. Turf Supply Company, Inc. filed a small-claims action against Roger Tavares, alleging that Tavares stopped payment on a check for services performed on his tractor. Tavares denied the allegations and counterclaimed for $2,500, asserting that the services were not rendered. The District Court ruled in favor of E.H. Turf Supply, awarding $1,500 plus costs. Tavares appealed to the Superior Court, arguing procedural errors and bias.The Superior Court held a de novo bench trial. E.H. Turf Supply presented testimony from its president, Erik Hagenstein, who detailed the company's repair process and confirmed that Tavares had approved and paid for the services before stopping payment. Tavares cross-examined Hagenstein and attempted to introduce invoices from other repair shops to show that the repairs were not properly done. The trial justice excluded these invoices as hearsay but allowed Tavares to testify about his experience.The Superior Court found in favor of E.H. Turf Supply, awarding $1,703.71. Tavares appealed to the Rhode Island Supreme Court, arguing that the Superior Court erred in allowing E.H. Turf Supply to present its case first, excluding his evidence, and not considering his status as a self-represented litigant.The Rhode Island Supreme Court reviewed the case and found no merit in Tavares's arguments. The Court held that E.H. Turf Supply, as the plaintiff, was correctly allowed to present its case first. The exclusion of the invoices was proper as they were hearsay, and the trial justice provided Tavares with ample opportunity to present his case. The Court affirmed the judgment of the Superior Court. View "E.H. Turf Supply Co. v. Tavares" on Justia Law

The defendant, Olayinka Alege, was charged with one count of simple assault and/or battery following an incident at the Edge Fitness club in Warwick, Rhode Island, where he allegedly removed a complaining witness's sock and shoe and massaged his foot without consent. The Warwick Police Department filed a criminal complaint on May 10, 2021, and the defendant was found guilty in the Third Division District Court on April 8, 2022. The case was then transferred to the Superior Court, where a mistrial was declared due to a hung jury. A new trial was scheduled, and the defendant's counsel withdrew, leading to the defendant representing himself.In the Superior Court, the defendant's motion for a Franks hearing was denied. The trial justice found that the statement in the affidavit, which indicated that surveillance video supported the complaining witness's version of events, was not materially false and that the complaining witness's statement alone supported probable cause. The trial justice also granted the state's motion in limine to admit testimony from Alexander Harrington under Rule 404(b) of the Rhode Island Rules of Evidence, finding it relevant to show intent or plan.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's judgment. The Court held that the trial justice did not abuse his discretion in denying the Franks hearing, as the affidavit contained sufficient content to support probable cause. The Court also upheld the admission of Harrington's testimony, agreeing that it was relevant to show intent or plan and that the trial justice provided appropriate limiting instructions to the jury. The Court found no error in the trial justice's denial of the defendant's motion to recuse, noting that the trial justice's actions demonstrated no personal bias or prejudice. Finally, the Court declined to consider the defendant's argument regarding sentencing, as he had not filed a Rule 35 motion and presented no extraordinary circumstances. View "State v. Alege" on Justia Law

Lieutenant Staci K. Shepherd, a Rhode Island State Police officer with a commendable 22-year career, suffered a heart attack during a firearms requalification program on May 2, 2017, which left her permanently disabled. She applied for a disability pension under Rhode Island law and the collective-bargaining agreement (CBA) between the State of Rhode Island and the Rhode Island Troopers Association. Superintendent Colonel James M. Manni denied her application, concluding that she failed to prove her heart attack was causally related to her employment. Shepherd then filed a declaratory-judgment complaint.The Superior Court found Superintendent Manni's decision arbitrary and capricious, declaring Shepherd entitled to a disability pension. The court criticized the superintendent's requirement for causation to a reasonable degree of medical certainty and his failure to consider the CBA's heart-attack presumption provision. The court granted Shepherd's motion for partial summary judgment, leading to the defendant's appeal.The Rhode Island Supreme Court reviewed the case de novo. The court noted that the superintendent applied an incorrect causation standard, requiring proof that the heart attack was caused by employment, rather than whether employment conditions contributed to the injury. The court emphasized that under the correct standard, it is sufficient if employment conditions contributed to the injury. Given the undisputed facts, including the stress and physical demands of Shepherd's job, the court concluded that her employment contributed to her heart attack. Consequently, the court affirmed the Superior Court's judgment, declaring Shepherd entitled to a disability pension. View "Shepherd v. Rhode Island State Police" on Justia Law

The defendant was arrested by the Rhode Island State Police on January 13, 2017, following allegations of child molestation by the complainant, A.R. During the post-arrest interview, the defendant admitted to various instances of sexual contact with A.R. Subsequently, the state filed a ten-count criminal information against the defendant, including eight counts of second-degree child molestation. The defendant moved to suppress his post-arrest statements, arguing they were involuntary and obtained in violation of his due process rights and Rule 5(a) of the District Court Rules of Criminal Procedure. He also sought to introduce expert testimony on false confessions, which the state moved to preclude.The Superior Court denied the defendant's motion to suppress, finding that his statements were made voluntarily and that the delay in presentment to the District Court was not causative of his confession. The court also granted the state's motion in limine to exclude the expert testimony on false confessions, reasoning that it would invade the jury's province and that effective cross-examination of the police would suffice. The jury found the defendant guilty on five counts of second-degree child molestation, and the trial justice denied the defendant's motion for a new trial.The Rhode Island Supreme Court reviewed the case and 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's statements were made voluntarily under the totality of the circumstances. The Court also upheld the exclusion of the expert testimony on false confessions, agreeing that it would improperly influence the jury's role in determining credibility. Finally, the Court found no error in the trial justice's denial of the motion for a new trial, as the trial justice had appropriately evaluated the evidence and witness credibility. View "State v. Coletta" on Justia Law

The plaintiffs, Daniel B. Struebing and Amanda L. Lyons, appealed from a summary judgment in favor of the defendants, Jeremy J. Fournier and Jennifer M. Fournier, in a case involving claims of trespass and adverse possession. The plaintiffs argued that a "seizure" by the United States government of their property interrupted the statutory period for the defendants' adverse possession claim. They also contended that the hearing justice improperly acted as a factfinder and overlooked a federal court's determination regarding the forfeiture of the property.The Superior Court initially denied the defendants' motion for summary judgment due to concerns about federal jurisdiction over the forfeiture proceedings. However, after the federal court clarified that it did not retain jurisdiction over the property dispute, the Superior Court granted the defendants' renewed motion for summary judgment. The court found that the defendants had satisfied the elements of adverse possession by clear and convincing evidence, having maintained and used the disputed area exclusively for over ten years.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's judgment. The court held that the federal government's actions did not constitute a seizure that interrupted the adverse possession period. The court also agreed that the defendants had established their adverse possession claim by clear and convincing evidence, noting their continuous and exclusive use of the property since 2008. Consequently, the plaintiffs' claims of trespass and slander of title were rendered moot. View "New Phase Realty, LLC v. Fournier" on Justia Law

Verizon New England Inc. (Verizon) sought review of a District Court judgment favoring Neena S. Savage, the Tax Administrator for Rhode Island. The case revolved around the interpretation of "accumulated depreciation" under G.L. 1956 § 44-13-13, which governs the taxation of tangible personal property (TPP) for telecommunications companies in Rhode Island. Verizon, a New York corporation providing telecommunications services in Rhode Island, had declared the value of its TPP based on financial accounting depreciation until 2009. After reevaluating its approach, Verizon submitted amended valuations and requested tax refunds, which were denied.Verizon requested an administrative hearing, arguing that "accumulated depreciation" should include all forms of depreciation, including physical deterioration, functional obsolescence, and economic obsolescence. The hearing officer recommended affirming the refund denials, and the tax administrator adopted this recommendation. Verizon then appealed to the District Court, claiming the tax was excessive due to the incorrect calculation of accumulated depreciation.The District Court granted summary judgment in favor of the defendant, reasoning that the plain and ordinary meaning of "accumulated depreciation" did not include external factors like obsolescence. The court noted that the tax administrator had consistently applied financial accounting-based depreciation for forty years without legislative intervention.The Rhode Island Supreme Court reviewed the case and agreed with the District Court's interpretation. The court held that "accumulated depreciation" in § 44-13-13 refers to financial accounting depreciation, reflecting the value on Verizon's balance sheet. The court affirmed the judgment of the District Court, concluding that the plain and ordinary meaning of depreciation did not encompass market contingencies such as economic and functional obsolescence. View "Verizon New England Inc. v. Savage" on Justia Law

The case involves allegations of child molestation against the defendant, who was indicted on one count of first-degree child molestation and two counts of second-degree child molestation. The complaining witness, a minor, accused the defendant of multiple instances of molestation occurring when she was between four and eight years old. The defendant was convicted by a jury on one count of first-degree child molestation and one count of second-degree child molestation. He was sentenced to a sixty-year sentence, with twenty-five years to be served, for the first-degree count, and a concurrent twenty-five-year sentence for the second-degree count.In the Providence County Superior Court, the trial justice granted the defendant’s motion for judgment of acquittal on one of the two counts of second-degree child molestation. The jury found the defendant guilty on the remaining counts. The defendant did not file a motion for a new trial. The trial justice later sentenced the defendant, and a judgment of conviction and commitment was entered.The defendant appealed to the Supreme Court of Rhode Island, arguing that the trial justice erred by allowing a medical expert to testify in a manner that impermissibly bolstered the complaining witness’s testimony. The Supreme Court of Rhode Island reviewed the case and determined that the defendant had not properly preserved his objection to the expert’s testimony for appellate review. The court noted that the defendant failed to object to the specific questions that formed the basis of his appeal and did not move to strike the expert’s answers or request a cautionary instruction. Consequently, the court deemed the issue waived and affirmed the judgment of the Superior Court. View "State v. Lantigua" on Justia Law

The plaintiffs, Robert and Etleva Stratoberdha, filed a lawsuit in Superior Court against Clements Properties, LLC, Robert P. Rucando, and officials from the Town of Portsmouth. They alleged that Clements Properties caused continuous trespass by creating an illegal drainage structure, Rucando failed to disclose flooding issues when selling the property, and the Town neglected to enforce ordinances. During the prolonged litigation, Etleva filed for divorce, and the Family Court issued orders related to the sale of the marital home and the settlement of the Superior Court action.The Family Court appointed a Commissioner to sell the marital home and authorized her to settle the Superior Court action. Robert did not appeal these orders. The Family Court later approved a settlement agreement where Clements Properties would buy the marital home for $870,000, and the Town would pay $75,000 in damages. The Family Court's orders and the settlement agreement were incorporated into the interlocutory decision pending entry of final judgment in the divorce case. Robert's appeal of this decision was dismissed as untimely.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's order approving the settlement agreement. The Court held that the Family Court's orders were final and could not be challenged in the Superior Court. The Superior Court's approval of the settlement agreement was a ministerial act based on the Family Court's final decrees. The Court found no merit in Robert's arguments and concluded that the Superior Court properly relied on the Family Court's orders. View "Stratoberdhav. Clements Properties, LLC" on Justia Law