Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the superior court denying Defendant's motion to dismiss one count of first-degree sexual assault on the grounds of double jeopardy and prosecutorial misconduct, holding that Defendant was not entitled to relief on his claims. Defendant was found guilty of assault and battery and acquitted as to several offenses, but as to the charge for first-degree sexual assault based upon anal penetration, the jury deadlocked and did not reach a verdict. When it became evident that the State would retry Defendant on the deadlocked count, Defendant filed several pretrial motions. Defendant filed a motion to dismiss the sole remaining count, arguing that double jeopardy barred a retrial of acquitted conduct that arose from the same set of facts previously decided by the jury and that the prosecutor engaged in misconduct. Defendant further sought to exclude any reference to acquitted conduct from the first trial. The trial justice denied Defendant's motions. The Supreme Court affirmed, holding (1) Defendant's first argument conflated a double jeopardy contention with one that was evidentiary, and whether Defendant's acquitted conduct was admissible under R.I. R. Evid. 404(b) at his retrial was an issue not properly before the court; and (2) Defendant's prosecutorial misconduct argument was not preserved for appeal. View "State v. Forlasto" on Justia Law

The Supreme Court affirmed the superior court judgment adjudicating Defendant a probation violator and a superior court order denying Defendant's motion to terminate imprisonment, holding that the hearing justices did not act arbitrarily or capriciously or err in denying Defendant's motions. Defendant pled guilty to first-degree sexual assault and assault with a dangerous weapon. Subsequently, Defendant pled nolo contendere to charges of failing to register as a sex offender. Later, a hearing justice adjudicated Defendant a probation violator by failing to keep the peace and be of good behavior. While his first appeal was pending, Defendant filed a pro se motion to terminate his sentence of imprisonment, asserting that the requirements of R.I. Gen. Laws 12-19-18(b)(5) were satisfied under the facts of his case. The hearing justice denied Defendant's motion. The Supreme Court affirmed, holding (1) the hearing justice did not act arbitrarily or capriciously in finding that Defendant had violated the terms of his probation; and (2) the second hearing justice did not err in denying Defendant's motion to terminate his imprisonment because there was ample evidence to support the conclusion that section 12-19-18(b)(5) was inapplicable to the instant case. View "State v. Murray" on Justia Law

The Supreme Court vacated the judgment of the superior court that granted a preliminary injunction in favor of Plaintiffs restraining the City of Woonsocket from changing the terms of Plaintiffs' retiree health insurance, holding that the City had the statutory authority to make changes to Plaintiffs' health care benefits. Plaintiffs, several retried Woonsocket police officers, brought this action against the City and the Woonsocket Budget Commission (the WBC). The superior court granted a preliminary injunction for Plaintiffs and reinstated Plaintiffs' previous postretirement health care benefits. The Supreme Court vacated the judgment, holding that the trial justice (1) did not err when he found that Plaintiffs had a vested contractual right to free lifetime health care benefits; (2) erred when he found that the WBC lacked statutory authority when it adopted the Retiree Resolutions that required Plaintiffs to contribute to their health care expenses; and (3) erred in finding that the WBC violated the Contract Clause of the Rhode Island Constitution when it required Plaintiffs to pay for their health insurance under a new uniform health care plan applicable to all retirees and employees. The Court remanded the case to the trial justice for additional findings. View "Hebert v. City of Woonsocket" on Justia Law

In this dispute among siblings regarding amendments to an inter vivos trust and gifts of interest in a family limited partnership established by Augusta Hathaway the Supreme Court affirmed the judgment of the superior court and vacated the grant of a new trial as to Plaintiff's breach of fiduciary duty claim, holding that the order granting a new trial was unnecessary. A jury found that Hathaway lacked the testamentary capacity to amend her trust and that Defendant Marion Louttit, Hathaway's daughter, had unduly influenced Hathaway, thereby causing Hathaway to execute challenged amendments and gifts. The jury further found that Louttit breached her fiduciary duty as trustee. After the jury's verdict, the trial justice granted Louttit's motion for new trial and judgment as a matter of law as to the fiduciary duty verdict because Plaintiff Wenda Branson, Hathaway's daughter, had failed to prove damages. The Supreme Court affirmed the judgment in all respects, holding (1) Branson's claims were not barred by the equitable doctrine of laches; (2) Louttit's motions for judgment as a matter of law and for new trial on the issue of undue influence was properly denied; and (3) the grant of a new trial on the issue of fiduciary duty is vacated as superfluous. View "Branson v. Louttit" on Justia Law

The Supreme Court affirmed in part and vacated in part the superior court's denial of Defendants' motion for a new trial after a jury found in favor of Plaintiff on his complaint alleging conversion and breach of contract, holding that Defendants waived their economic loss doctrine argument and that the trial justice erred in awarding attorneys' fees to Plaintiff. Plaintiffs entered into a lease with Defendants to rent commercial property owned by Defendants. Plaintiff was unable to occupy the commercial premises before the lease period could begin, but Defendants refused to return the security deposit. Plaintiff filed this action, alleging and breach of contract and that the refusal to return the security deposit constituted a conversion of his property. A jury found that Defendants had converted Plaintiff's security deposit to their own use. Judgment entered awarding Plaintiff compensatory damages plus attorneys' fees. Plaintiffs appealed, arguing that the economic loss doctrine barred recovery under the conversion claim and that the trial justice erred in awarding attorneys' fees pursuant to R.I. Gen. Laws 9-1-45. The Supreme Court held (1) Defendants waived the economic loss doctrine argument and may not now revive the argument on appeal; and (2) section 9-1-45 cannot be the basis for an attorneys' fees award in this case. View "Heneault v. Lantini" on Justia Law

The Supreme Court quashed the judgment of the superior court upholding the decision of the Administrative Adjudication Division (AAD) of the Rhode Island Department of Environmental Management (DEM) denying Plaintiffs' request for reasonable litigation expenses in this case alleging violations of the Rhode Island Water Pollution Act (Act) and other regulations, holding that Plaintiffs were entitled to reasonable litigation expenses. Plaintiffs appealed from a notice of violation issued by the DEM alleging ten violations of the Act, the Rhode Island Oil Pollution Control Act, and DEM's regulations. After a hearing before the AAD, Plaintiffs prevailed on all but two of the alleged violations. Plaintiffs requested reasonable litigation expenses under the Equal Access to Justice for Small Businesses and Individuals Act (EAJA), but the AAD hearing officer denied the request. The superior court affirmed. The Supreme Court quashed the superior court's decision, holding that DEM Acted without substantial justification in pursuing charges against Plaintiffs and that this was the type of unjust action by the State that the EAJA was designed to ameliorate. The Court remanded the case with directions to enter a judgment in favor of Plaintiffs in the amount of $69,581.25 for attorneys' fees. View "Rollingwood Acres, Inc. v. Rhode Island Department of Environmental Management" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Petitioner's appeal from a decision of a drug court magistrate upholding a determination by the Sex Offender Board of Review classifying Petitioner as a Level II, moderate-risk sex offender, holding that Petitioner's classification was lawful and proper. On appeal, Petitioner argued that the Board violated his rights to due process, to the presumption of innocence, and to be protected from double jeopardy by relying on alleged impermissible hearsay allegations for conduct for which he was eventually acquitted. The Supreme Court affirmed, holding (1) Petitioner failed to demonstrate that his right to procedural due process was violated; (2) the Board considered numerous factors in making its determination; and (3) Petitioner's classification did not violate the Double Jeopardy Clause, and the Board's actions were not in the context of a criminal trial and did not implicate Petitioner's right to a fair trial. View "DiCarlo v. State" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendants on Plaintiff's complaint alleging various claims under, inter alia, the Rhode Island Wiretap Act, state privacy laws, and federal laws after Defendants installed software on Plaintiff's work computer without his knowledge that intercepted Plaintiff's emails and online activities, holding that summary judgment was properly granted. Plaintiff was employed by Defendants before his arrest and eventual conviction for possession of child pornography. Defendant had installed tracking software on Plaintiff's work computer that recorded Plaintiff's online activities and emailed the record to Defendants. The hearing justice found that the intercepted information was disclosed to the police department, leading to Plaintiff's arrest and conviction, that the claims set forth in Plaintiff's complaint were barred by limitations, and that there was no evidence indicating that Defendants had fraudulently concealed the conduct that formed the basis of Plaintiff's computer crime claims. The Supreme Court affirmed, holding (1) Plaintiff's claims were time-barred; (2) Plaintiff could not benefit from the tolling provisions of R.I. Gen. Laws 9-1-20; and (3) the continuing violation doctrine did not apply to Plaintiff's Rhode Island Wiretap Act claim against Defendants. View "Boudreau v. Automatic Temperature Controls, Inc." on Justia Law

The Supreme Court affirmed the judgment of the superior court reversing the Rhode Island Airport Corporation's (RIAC) 2015 order prohibiting Plaintiff from entering the North Central State Airport, holding that RIAC was not cloaked with the inherent authority to preclude an individual from entering an airport within its jurisdiction without having first issued a formal order. Before the Supreme Court, RIAC argued that it had the authority to ban an individual from any of its airports without issuing a formal order if that individual poses a threat to airport safety or operations and, in there alternative, the no-trespass letter issued by RIAC's attorneys in 2014 and the order issued by RIAC's direction in 2015 could be considered a valid final order the complied with all statutory requirements. The Supreme Court held (1) an order issued by RIAC's director pursuant to R.I. Gen. Laws 1-4-15 is the exclusive means of permanently barring an individual from entering onto an airport on RIAC's jurisdiction; and (2) neither communication sent in this case constituted a valid formal order. View "Blais v. Rhode Island Airport Corp." on Justia Law

In this dispute over the cost of annual premiums for post-retirement life insurance benefits the Supreme Court affirmed the judgment of the superior court entering summary judgment in favor of Plaintiffs - the Rhode Island American Federal of Teachers/Retired Local 8307 and several retirees of the Johnston School Department - holding that the trial justice correctly interpreted R.I. Gen. Laws 16-16-42. Before the Supreme Court, both Plaintiffs and Defendants - the Town of Johnston, the Johnston School Department, the Johnston School Committee, and various municipal officials - argued that section 16-16-42, entitled "Life insurance benefits," is clear and unambiguous, but each party posited a different interpretation. The Supreme Court affirmed the decision of the superior court justice, holding that a proper interpretation of the statute provides that any teacher who, at the time of retirement from service or last day of active employment, has in effect life insurance provided for as a benefit of his or her employment shall, after retirement, be entitled to keep the life insurance policy in effect by paying to the municipality an amount equal to the annual cost of the policy for the individual at the time of the individual's retirement or last day of active employment. View "Rhode Island American Federation of Teachers/Retired Local 8037 v. Johnston School Committee" on Justia Law