Justia Rhode Island Supreme Court Opinion Summaries

The Providence Retired Police and Firefighter’s Association (the Association) sought a declaratory judgment against the City of Providence (the city) regarding entitlement to occupational cancer disability benefits under Rhode Island General Laws chapter 19.1 of title 45, “Cancer Benefits for Fire Fighters.” The Association argued that its retired members were entitled to these benefits under the state law, while the city contended that benefits should be processed under a local ordinance.The Superior Court granted partial summary judgment in favor of the Association, concluding that the state law applied to all firefighters, including those retired from the Providence Fire Department, regardless of the city's participation in the Municipal Employees Retirement System (MERS). The court relied on the Rhode Island Supreme Court's decision in City of East Providence v. International Association of Firefighters Local 850, which interpreted the state law to apply broadly to all firefighters.The Rhode Island Supreme Court reviewed the case and vacated the Superior Court's judgment. The Supreme Court held that the Providence System, a comprehensive retirement benefits program established by a special legislative act, supersedes the general state statute. The court referenced its prior decision in Betz v. Paolino, which established that special legislative provisions for the Providence System prevail over state statutes of general application. Consequently, the court determined that the city is not required to process applications for occupational cancer benefits under the state law but should follow the local ordinance. The case was remanded to the Superior Court with instructions to enter judgment for the city. View "The Providence Retired Police and Firefighter's Association v. The City of Providence" on Justia Law

The plaintiff, Paula M. Montaquila, appealed a decision granting summary judgment in favor of the defendant, Flagstar Bank, FSB, regarding the foreclosure sale of property located at 33 Zella Street in Providence, Rhode Island. Ms. Montaquila and her son had obtained a mortgage with Flagstar in 2008, using the property as collateral, and later executed a partial claim mortgage in 2016. Flagstar sent a notice of intent to foreclose to the property via certified mail and conducted a foreclosure sale, which Ms. Montaquila challenged, alleging that Flagstar failed to comply with statutory notice requirements by not sending the notice to her last known address at 25 Enfield Avenue.The Superior Court granted Flagstar's motion for judgment on the pleadings, which was affirmed in part and vacated in part by the Rhode Island Supreme Court. The case was remanded for further proceedings to determine whether Flagstar had satisfied the statutory notice requirements as to Ms. Montaquila. On remand, Flagstar filed a motion for summary judgment, arguing that it had complied with the notice requirements by sending the notice to the property address, where Ms. Montaquila was listed as an assessed owner.The Rhode Island Supreme Court reviewed the case de novo and concluded that there were no genuine issues of material fact regarding Flagstar's compliance with the statutory notice requirements. The court held that the last generally recognized address for Ms. Montaquila, relating to the real estate subject to the mortgage, was 33 Zella Street. Flagstar had complied with the statutory requirements by sending the notice to that address. Consequently, the court affirmed the judgment of the Superior Court, granting summary judgment in favor of Flagstar. View "Montaquila v. Flagstar Bank, FSB" on Justia Law

The petitioner, Charles Pona, sought review of two orders from the Superior Court that summarily dismissed his applications for postconviction relief from two murder convictions. Pona was indicted in 2000 for the murder of Hector Feliciano and later orchestrated the murder of a witness, Jennifer Rivera, in 2003. He was convicted of Feliciano's murder in 2000 and Rivera's murder in 2010 after a retrial. Pona's applications for postconviction relief alleged that the Superior Court fraudulently obtained jurisdiction over him, transforming him from a natural person into an artificial person.The Superior Court issued a notice of intention to dismiss Pona's applications, stating that his claims were specious. Pona responded, reiterating his original contentions. The hearing justice dismissed the applications without a hearing, concluding that Pona's claims were baseless and noting that Pona did not request an attorney and entered his appearances pro se.The Rhode Island Supreme Court reviewed the case and focused on whether Pona was denied his statutory right to counsel as a first-time applicant for postconviction relief under § 10-9.1-5. The Court held that an indigent, first-time applicant is entitled to counsel before summary dismissal of their application, even if the claims appear meritless. The Court found that Pona's waiver of his right to counsel was not verified as knowing, intelligent, and voluntary since no hearing was conducted.The Rhode Island Supreme Court quashed the Superior Court's orders and instructed the lower court to conduct a hearing to determine whether Pona intended to proceed pro se and if his decision was made knowingly, voluntarily, and intelligently. View "Pona v. State of Rhode Island" on Justia Law

In 1991, Francisco Martinez was indicted on charges including first-degree murder and assault with a dangerous weapon. In 1993, he was convicted and sentenced to life imprisonment for the murder and a consecutive twenty-year sentence for the assault, with five years to serve and the remainder suspended with probation. Martinez's convictions were affirmed in 1995. In 2021, Martinez filed for postconviction relief, arguing that his sentences should be aggregated for parole eligibility, making him eligible after serving 16 years and 8 months. He claimed that the Rhode Island Department of Corrections (RIDOC) had unlawfully altered its method of calculating parole eligibility, requiring him to be paroled from his life sentence to his consecutive sentence before being eligible for release to the community.The Superior Court granted Martinez's application for postconviction relief, ruling that his sentences should be aggregated and ordering the Parole Board to release him to the community. The state petitioned for a writ of certiorari, arguing that the hearing justice erred in aggregating the sentences and in ordering Martinez's immediate release.The Rhode Island Supreme Court reviewed the case. Citing its recent decision in Neves v. State, the Court affirmed the aggregation of Martinez's sentences for parole eligibility purposes. However, the Court quashed the part of the Superior Court's judgment that ordered Martinez's immediate release to the community, holding that the hearing justice exceeded his authority. The Parole Board had only paroled Martinez to his consecutive sentence, not to the community, and the normal parole processes must be followed before any release to the community can be considered. The case was remanded to the Superior Court with instructions to remand it to the Parole Board for further proceedings. View "Martinez v. State of Rhode Island" on Justia Law

The plaintiffs, City of Warren Police and Fire Retirement System and David Freundlich, filed a consolidated securities action against CVS Health Corporation. They alleged that CVS's offering documents related to its 2018 merger with Aetna contained false statements and omissions, violating sections 11, 12(a)(2), and 15 of the Securities Act of 1933. The plaintiffs claimed that CVS overstated the value of its goodwill and failed to disclose significant issues with its Long Term Care (LTC) business, which it acquired through Omnicare, Inc. in 2015.The Superior Court of Rhode Island dismissed the plaintiffs' Revised Amended Consolidated Complaint (RACC), finding that the plaintiffs failed to state a claim under the Securities Act. The court also noted that similar claims had been dismissed in related cases in New York and the First Circuit. The plaintiffs appealed the dismissal, arguing that the Superior Court improperly applied collateral estoppel and failed to consider the merits of their claims.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's dismissal. The Supreme Court held that the plaintiffs waived their right to challenge the merits of the dismissal by not adequately addressing it in their initial brief. The court also found that the Superior Court's decision to dismiss the case was supported by principles of judicial economy and comity, given the similar rulings in related cases. The Supreme Court concluded that the plaintiffs' appeal was without merit and upheld the lower court's judgment. View "In re CVS Health Corporation Securities Litigation" on Justia Law

The petitioner was found guilty of first-degree murder for the brutal stabbing of his then-wife's sixteen-year-old daughter and was sentenced to life imprisonment without the possibility of parole, plus an additional fifteen years as a habitual offender. On direct appeal, the Rhode Island Supreme Court affirmed the conviction and life sentence but vacated the additional fifteen-year sentence.The petitioner later filed a pro se application for postconviction relief, alleging ineffective assistance of counsel for failing to present mitigating evidence at sentencing. The Superior Court denied the application, finding that the trial counsel's performance was not deficient and that the petitioner was not prejudiced by any alleged deficiencies. The court noted that trial counsel made a strategic decision not to call the petitioner’s doctor to testify, as it could have negatively impacted the case.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's judgment. The court held that the petitioner failed to demonstrate that his trial counsel's performance was constitutionally deficient under the Strickland v. Washington standard. The court found that trial counsel's decision not to call the petitioner’s doctor was a strategic choice based on the potential risks of cross-examination. Additionally, the court noted that the petitioner’s mental health records were included in the presentence report, which the trial justice considered during sentencing. The court concluded that the petitioner did not meet his burden of showing that the outcome of the sentencing would have been different but for the alleged errors by trial counsel. View "Smith v. State" on Justia Law

The plaintiff, Willie Gray, filed a complaint for personal injuries sustained in a fire at a multifamily residential property in Providence on January 12, 2018. The property was allegedly owned by Dexter Jackson, whose negligence was claimed to have caused the fire. The City of Providence was also named as a defendant for being aware of several housing code violations at the property from January 2015 through January 2018. The plaintiff failed to provide adequate responses to the defendant's discovery requests, leading to a motion to compel and subsequent orders to produce more responsive answers.The Superior Court granted the defendant's motion to compel and later a motion to enter final judgment against the plaintiff due to non-compliance with discovery orders. The plaintiff did not object to these motions and failed to appear at the hearing for the renewed motion for entry of final judgment. The Superior Court denied the plaintiff's subsequent motion to vacate the order granting final judgment, citing a lack of objection and failure to comply with discovery requirements.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's order. The Court found that the plaintiff had ample opportunity to comply with discovery obligations and failed to do so. The trial justice did not abuse his discretion or commit an error of law in denying the plaintiff's motion for relief. The appeal was considered interlocutory, but the Court proceeded to evaluate the merits due to the futility of remanding for default judgment against Jackson, who had not participated in the litigation. The order of the Superior Court was affirmed. View "Gray v. City of Providence" on Justia Law

The plaintiffs, Mill Road Realty Associates, LLC, Morris Maglioli, and William L. Ricci, Jr., d/b/a Wright’s Auto Parts, operated a junkyard in Foster, Rhode Island. They violated the conditions of their municipal license and continued operations despite a cease-and-desist letter from the Town’s zoning officer. Their municipal license expired, leading to the nonrenewal of their state license. Despite this, they continued operations without either license from 2018 to 2021. The Town issued another cease-and-desist letter in September 2021 and imposed a $100-per-day fine. The plaintiffs appealed to the zoning board of review, which denied their appeal. They then sought judicial review in Superior Court, alleging arbitrary, capricious, and tortious conduct by the defendants and seeking declaratory, injunctive, and monetary relief.The Superior Court dismissed the plaintiffs’ action under Rule 12(b)(1) for lack of subject-matter jurisdiction, citing the plaintiffs' failure to notify the attorney general of their constitutional claims as required by G.L. 1956 § 9-30-11. The trial justice dismissed the case sua sponte at the start of the hearing without allowing the parties to present evidence or argument on the issue of compliance with § 9-30-11.The Rhode Island Supreme Court reviewed the case and concluded that the trial justice erred by not providing the plaintiffs an opportunity to present evidence or argument on the issue of compliance with § 9-30-11 before dismissing the case. The Supreme Court vacated the order and judgment of the Superior Court and remanded the case for further proceedings, instructing the trial justice to allow the parties to present evidence on the issue of compliance with § 9-30-11 and the grounds for their initial motions. View "Mill Road Realty Associates, LLC v. Town of Foster" on Justia Law

The case involves a partition action concerning two properties in Charlestown, Rhode Island, owned by Peter Karasuk, Lee Karasuk Ingley, and Sandra Karasuk Puchalski as joint tenants with a right of survivorship. The properties were inherited from their mother’s estate in 2017. After failed negotiations to sell the properties to Puchalski, Karasuk and Ingley filed a partition action on May 3, 2021. Numerous continuances were granted due to Puchalski's complaints of hearing impairment. Despite accommodations, Puchalski expressed dissatisfaction and failed to appear at several hearings.The Superior Court dismissed Puchalski’s appeals, approved the commissioner’s petition for instructions, and quashed a statement she filed in the Town of Charlestown Land Evidence Records. Puchalski appealed these decisions. The Superior Court had granted plaintiffs' motion to sell the properties, appointed a commissioner, and issued a temporary restraining order against Puchalski. Puchalski failed to appear at critical hearings, leading to the dismissal of her appeals.The Rhode Island Supreme Court reviewed the case and found that Puchalski received adequate notice of the motions and hearings. The court determined that the orders appealed from were interlocutory and not subject to review under the exceptions to the final-judgment rule. The court affirmed the Superior Court’s decisions, including the dismissal of Puchalski’s appeals and the orders related to the partition and sale of the properties. The court emphasized that Puchalski’s continued attempts to delay the proceedings were unavailing and that the matter should proceed to finality. View "Karasuk v. Puchalski" on Justia Law

The plaintiff, Walter L. Bronhard, doing business as Walter L. Bronhard Real Estate, filed a lawsuit against the Thayer Street District Management Authority (TSDMA). The dispute arose after TSDMA allegedly sent an email to one of Bronhard's employees regarding the illegal dumping of boxes in Fones Alley. Bronhard's counsel claimed that TSDMA had been operating without legal authority since 2009 because it failed to file the required continuation petition within the statutory deadline, thus automatically dissolving as per the District Management Authorities Act.The Superior Court granted summary judgment in favor of TSDMA. The court found that although TSDMA did not file the continuation petition within the statutory deadline, the time constraint was directory rather than mandatory. The court applied the factors from West v. McDonald, determining that the statute did not contain a sanction for late filing, the time limitation was not the essence of the statute, and the deadline was directed at public officers. Consequently, the court concluded that TSDMA did not automatically dissolve and had been operating lawfully.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's judgment. The Supreme Court agreed that the time constraint in the statute was directory and not mandatory. The court held that the essence of the statute was to ensure active DMAs serve their communities, and TSDMA had substantially complied with the statute's purpose. Therefore, TSDMA's failure to meet the filing deadline did not result in its automatic dissolution. View "Bronhard v. Thayer Street District Management Authority" on Justia Law