Justia Rhode Island Supreme Court Opinion Summaries

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

Dorothy Apostolico, after her husband’s death, deeded a house in Cranston, Rhode Island to her three children, reserving a life estate for herself. The deed did not specify who was responsible for property taxes. Dorothy lived in the house until 2023, after which her son Domenic Apostolico resided there. The property did not produce any income during Dorothy’s life tenancy. Domenic paid property taxes during this time and sought reimbursement from his sister, Deborah Pagliaro, for her share of those taxes. After failed written requests, Domenic initiated a lawsuit seeking contribution and unjust enrichment.The Providence County Superior Court first dismissed Domenic’s original claim for contribution but allowed him to amend his complaint. Domenic then filed an amended complaint seeking Deborah’s share of taxes from 2010 onward. He moved for partial summary judgment on the issue of Deborah’s liability for taxes. Deborah objected and filed a cross-motion for summary judgment. The Superior Court, applying the precedent from Koszela v. Wilcox, 538 A.2d 150 (R.I. 1988), ruled that since the property was not income-producing, the responsibility for taxes fell to the remaindermen. The court granted Domenic’s motion as to liability, denied it as to the specific amount, and final judgment was entered for Domenic in the amount of $38,466.42.On appeal, the Supreme Court of Rhode Island affirmed the Superior Court’s judgment. The Court held that, under Rhode Island law, where a life estate property does not produce income, remaindermen—not the life tenant—are responsible for property taxes, regardless of whether the property is developed or the life tenant resides there. The Court also rejected Deborah’s statutory arguments, finding Koszela controlling and the statutes not in conflict with this rule. View "Apostolico v. Pagliaro" on Justia Law

The case involves a defendant who was charged with several drug-related offenses in two separate incidents, each involving multiple codefendants. The same attorney, David A. Cooper, entered his appearance to represent the defendant in both matters. During bail hearings in the Rhode Island Superior Court, the trial justice expressed concern about a potential conflict of interest because Attorney Cooper had previously represented one of the codefendants in a related matter. The trial justice questioned both the attorney and the defendant about this issue, and the defendant indicated that she understood the situation and wanted to continue with her chosen counsel, expressing her willingness to waive any potential conflict.Despite the defendant’s statements, the Superior Court trial justice removed Attorney Cooper as counsel, citing a “strong potential for conflict,” even though there was no actual conflict at the time. The court’s order was based on the attorney’s prior representation of a codefendant and the possibility that interests might diverge in the future, and a written waiver from the codefendant was obtained, while the defendant’s waiver was made orally in open court.The Supreme Court of Rhode Island reviewed the matter on writs of certiorari. The Supreme Court concluded that, although trial courts have discretion to remove counsel when there is an actual or serious potential conflict of interest, such a removal must be supported by a substantial showing that the likelihood and dimensions of the feared conflict are significant. The Supreme Court held that, in this case, the record did not support a sufficient showing of a substantial potential conflict to justify overriding the defendant’s chosen counsel at that time. Accordingly, the Supreme Court quashed the Superior Court’s orders removing Attorney Cooper as counsel and remanded the case. View "Viera v. State" on Justia Law

Two children were placed in the temporary custody of the Department of Children, Youth, and Families (DCYF) by the Family Court in 2018. The Family Court determined that Newport and Cumberland were responsible municipalities for the children’s education, as they were the residences of the custodial parents. DCYF placed the children in residential treatment facilities where they received general education services, but not special education services.DCYF requested orders from the Commissioner of Elementary and Secondary Education that Newport and Cumberland reimburse DCYF for education costs at the per-pupil special-education rate. The commissioner agreed and ordered the municipalities to pay at that rate. Both municipalities appealed to the Council on Elementary and Secondary Education, which denied their appeals. The municipalities then appealed to the Rhode Island Superior Court under the Administrative Procedures Act. The Superior Court consolidated the cases and found that the statute required the municipalities to pay their share of educational costs, but not at the special-education rate unless special education services were provided. The trial justice also held that, even after statutory amendments removed references to general education, the municipalities were still responsible for the per-pupil general-education rate for children not receiving special education.On review, the Supreme Court of Rhode Island considered whether the municipalities were obligated to pay the general-education rate after the statutory reference to general education was removed. The Court held that the plain language of the statute only requires reimbursement for special education costs and does not obligate municipalities to pay for general education where no special education services are provided. The Supreme Court quashed the decision of the Superior Court. View "Newport School Committee v. Rhode Island Department of Education" on Justia Law

The parties in this case, who were never married but cohabitated and share two minor children, separated in early 2023 after their relationship deteriorated. The plaintiff filed a complaint in the Kent County Family Court seeking joint custody, primary placement of the children, and child support. Shortly after, the defendant filed a separate complaint alleging abuse, resulting in an ex parte temporary protection order and temporary custody for her. Over the following year, the Family Court issued various orders, including appointing a guardian ad litem, scheduling mediation, amending visitation, and addressing discovery issues related to the plaintiff’s income.After several hearings, the Family Court entered four orders on June 25, 2024. These included a visitation order (not challenged on appeal), an order granting primary placement of the children to the defendant, a child-support guideline worksheet setting the plaintiff’s monthly obligation at $1,254, and a handwritten order memorializing child-support details and other arrangements. The plaintiff objected, contending that there was no agreement or sufficient opportunity to present evidence, and that the best interests of the children were not properly considered.The Supreme Court of Rhode Island reviewed the case. It found that the Family Court did not make adequate factual findings regarding the children’s best interests to support the order granting primary placement to the defendant, as required by established precedent. Accordingly, the Supreme Court vacated the disputed portion of the placement order. However, the Court affirmed the child-support guideline worksheet, determining that the plaintiff was bound by his attorney’s actions in signing the worksheet and that no special circumstances warranted overturning it. As the same support amount was memorialized in the handwritten order, the plaintiff’s appeal of that order was deemed moot. The case was remanded to the Family Court for further proceedings. View "Conway v. Orenberg" on Justia Law

A defendant was charged with multiple counts of child molestation sexual assault involving his biological daughter, referred to as Maria, who was fourteen years old at trial. The alleged incidents took place when Maria was around eleven and occurred during visits with her father, including one on a bus and another at her paternal grandmother’s residence. Maria did not immediately report the assaults due to fear and concern for her father but eventually disclosed them to a friend, a program instructor, and ultimately to medical professionals. At Hasbro Children’s Hospital and its Aubin Child Protection Center, Maria was evaluated physically and mentally, and she recounted the assaults to Dr. Barron, a specialist in child-abuse pediatrics.In the Providence County Superior Court, two counts were dismissed—one by the prosecution and one by the trial justice following a motion for acquittal. The jury found the defendant not guilty on one count and guilty on another, resulting in a life sentence. The defense’s pretrial motions sought to exclude Dr. Barron’s testimony, arguing that Maria’s statements to her were not made for medical diagnosis or treatment but for evidence collection. The trial justice allowed the testimony, finding it related to Maria’s diagnosis and treatment, especially given her mental health concerns and risk of self-harm.On appeal, the Supreme Court of Rhode Island reviewed whether challenged hearsay statements made by Maria to Dr. Barron were properly admitted under Rule 803(4) of the Rhode Island Rules of Evidence. The Court held that, except for one preserved objection, the defendant had waived the hearsay objections by failing to renew them at trial. The Court further concluded that the admitted statement was pertinent to medical diagnosis and treatment and, even if it were not, its admission was harmless as it was cumulative of other properly admitted evidence. The judgment of conviction was affirmed. View "State v. Cable" on Justia Law

A tenured teacher employed by a city was charged with a criminal offense, resulting in his placement on paid administrative leave. Over a year later, while the charge was still pending, the city changed the teacher's status to unpaid suspension. The teacher’s union filed a grievance contesting the unpaid suspension, leading to arbitration, where the arbitrator determined that the city had good and just cause for the suspension without pay. After the criminal charge was dismissed, the city reinstated the teacher. The union then filed a second grievance seeking back pay for the period of unpaid suspension, which both parties agreed to arbitrate.Following this, while the arbitration on the back-pay grievance was still pending, the teacher independently filed an action for declaratory relief in the Providence County Superior Court, seeking a declaration that he was entitled to back pay under the Teachers’ Tenure Act. The city moved to dismiss, arguing that the teacher had already selected the grievance and arbitration process as his remedy. The trial justice granted the motion, citing the election of remedies doctrine and relying on precedent, specifically Martone v. Johnston School Committee, which precludes pursuing multiple remedies for the same dispute when a party has already elected a process under a collective bargaining agreement.The Supreme Court of Rhode Island reviewed the case and affirmed the Superior Court’s dismissal. The Court held that once a party elects to pursue a remedy through the grievance and arbitration procedures in a collective bargaining agreement, they are foreclosed from simultaneously or subsequently seeking judicial relief for the same dispute under the doctrine of election of remedies. The disposition by the Supreme Court of Rhode Island was to affirm the lower court’s judgment. View "Peasley v. City of Providence" on Justia Law

A dispute arose regarding the sale of property located at 301 Harris Avenue in Providence, Rhode Island. The plaintiff, 1100 North Main LLC, sought to purchase property from the Providence Firefighters Realty Corp. (the Firefighters), contingent on the Firefighters acquiring replacement property. The Firefighters entered into negotiations with the defendant, Shoreby Hill Properties, Inc., to purchase the Harris Avenue property. After several communications, the Firefighters signed a draft purchase and sales agreement for the property, but the defendant refused to execute it and reportedly accepted another offer. The plaintiff then filed a complaint seeking declaratory, equitable, or monetary relief based on the alleged contract, and recorded two notices of lis pendens against the Harris Avenue property.In the Providence County Superior Court, the defendant moved to dismiss the complaint, quash the lis pendens, and sought sanctions. The plaintiff argued that the attorneys’ communications constituted assent and that a purported assignment from the Firefighters gave the plaintiff standing. Before the Superior Court justice issued a decision, the plaintiff attempted to amend its complaint to add factual allegations and clarify standing. The trial justice dismissed the complaint and quashed the lis pendens, finding that the allegations failed to satisfy the statute of frauds and did not establish standing. The motion to amend was denied as futile, as no enforceable contract was found.On appeal, the Supreme Court of Rhode Island reviewed whether a binding contract existed under the statute of frauds and whether denial of the motion to amend was proper. The Supreme Court held that the unsigned purchase and sales agreement did not satisfy the statute of frauds and no binding contract existed. The Court affirmed the Superior Court’s dismissal of the complaint, quashing of the lis pendens, and denial of the motion to amend. View "1100 North Main LLC v. Shoreby Hill Properties, Inc." on Justia Law

The plaintiff filed a domestic-abuse complaint in Rhode Island District Court, alleging that the defendant forced her to engage in sexual relations by force or duress. An ex parte temporary protective order was issued, prohibiting contact and requiring the defendant to surrender firearms. Following a hearing, the District Court granted a final order of protection for three years, continuing the firearm restrictions under relevant Rhode Island statutes.The defendant appealed to the Kent County Superior Court, which held a de novo bench trial. At trial, the judge stated he would apply a clear and convincing evidence standard, rather than the preponderance of the evidence standard typically used in civil cases, due to the temporary deprivation of the defendant’s firearm rights. The judge concluded that the plaintiff did not meet this higher burden of proof, found the defendant’s evidence more credible, and dismissed the complaint, dissolving the protective order. The plaintiff then appealed to the Rhode Island Supreme Court.The Rhode Island Supreme Court reviewed the case de novo, focusing solely on the appropriate burden of proof for civil protective orders involving temporary restrictions of firearm rights. The Court held that the preponderance of the evidence is the correct standard in such proceedings, notwithstanding the Second Amendment implications or statutory provisions regarding firearm surrender. The Court found no legislative intent to require a higher standard, and emphasized that temporary restrictions do not amount to a significant deprivation of liberty requiring heightened proof. Accordingly, the Supreme Court vacated the Superior Court’s judgment and remanded for a new hearing under the preponderance of the evidence standard. View "Andrew v. Adorno" on Justia Law

The plaintiffs owned property in Cumberland, Rhode Island, adjacent to land operated as an automotive recycling facility by the defendants. They alleged that environmental contamination from the facility affected their property. The litigation began in 2006, and after years of procedural developments, the first jury trial in 2012 resulted in a judgment for the plaintiffs. However, the Rhode Island Supreme Court later found that the trial justice had erroneously excluded expert testimony and ordered a new trial.A second jury trial was held in 2020 in the Rhode Island Superior Court. During this trial, plaintiffs’ counsel objected to statements made by defense counsel in his opening, arguing that certain factual assertions were inaccurate. Plaintiffs also objected to the testimony of defense witness Karen Beck, claiming her expert opinion should not include references to a report she had not relied on when forming her initial conclusions. The trial justice issued a curative instruction addressing the opening statement objections and limited Beck’s testimony to certain aspects of the disputed report. The jury returned a verdict for defendants, except for a $10,000 punitive damages award against one defendant, which was later vacated by amended judgment. Plaintiffs appealed, and subsequent procedural delays occurred regarding the transmission of the appellate record.On appeal, the Supreme Court of Rhode Island addressed whether the plaintiffs’ appeal should be dismissed for procedural delay and whether the trial justice erred regarding the curative instruction and Beck’s testimony. The court held that dismissal was unwarranted since plaintiffs timely ordered transcripts and took reasonable steps regarding the record. The court further held that plaintiffs had waived their objection to the curative instruction by failing to object at trial, and that the limitations placed on Beck’s testimony did not constitute an abuse of discretion. The amended judgment of the Superior Court was affirmed. View "Paolino v. Ferreira" on Justia Law