Justia Rhode Island Supreme Court Opinion Summaries

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The Supreme Court affirmed in part and quashed in part the judgment of the superior court affirming a decision of the Town of Charlestown Zoning Board of Review denying a special-use permit and a dimensional variance, holding that there was insufficient evidence to support the denial of the special-use permit.New Castle Realty Company applied to the zoning board for a special-use permit and a dimensional variance to build a house and install a septic system on a preexisting nonconforming lot. The zoning board denied both requests. The Supreme Court affirmed in part and quashed in part the superior court's judgment, holding (1) substantial evidence did not exist in the record to support either the zoning board's decision to deny the special-use permit or the trial justice's ruling affirming the denial of the special-use permit; and (2) the trial justice correctly concluded that certain testimony was fatal to New Castle's request for a dimensional variance. View "New Castle Realty Co. v. Dreczko" on Justia Law

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The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendant, as trustee of the Trust of Anna H. Blankstein, and dismissing Plaintiff's complaint for an accounting pursuant to R.I. Gen. Laws 18-13-15(b), holding that Plaintiff was not entitled to relief.Plaintiff, the beneficiary of the Trust of Anna H. Blankstein, brought this action requesting an accounting pursuant to the Rhode Island Uniform Custodial Trust Act (RIUCTA). Defendant moved for summary judgment, arguing that, by its terms, the trust was not a custodial trust, and therefore, Plaintiff was not entitled to an accounting of the trust. The trial justice granted summary judgment in favor of Defendant. The Supreme Court affirmed, holding (1) Blankstein did not create a custodial trust because the trust did not meet the requirements set forth in RIUCTA; and (2) Plaintiff did not have standing as the administrator of the estate to request an accounting. View "Shorr v. Harris" on Justia Law

Posted in: Trusts & Estates
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The Supreme Court affirmed the judgment of the superior court denying Defendant's renewed motion for judgment as a matter of law or, in the alternative, a motion for a new trial, holding that the trial justice did not err in denying the motions.A dispute over certain real property resulted in litigation and a jury trial. Plaintiff bought an eight-count amended complaint against Defendant. The jury was instructed to consider only Plaintiff's promissory estoppel and unjust enrichment claims, and the jury rendered a verdict in favor of Plaintiff on those counts. The Supreme Court affirmed, holding that Defendant was not entitled to judgment as a matter of law or a new trial as to the promissory estoppel and unjust enrichment claims. View "Salvatore v. Palangio" on Justia Law

Posted in: Contracts
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The Supreme Court affirmed the judgment of the superior court convicting Defendant of second-degree murder, receiving stolen goods, conspiracy, operating a vehicle on a suspended license, and carrying a knife greater than three inches in length, holding that there was no error.Specifically, the Supreme Court held (1) the trial justice did not err in denying Defendant's motion to suppress the fruits of his third interrogation; (2) the trial justice did not err by declining to redact certain prejudicial statements Defendant made while he was alone in the interrogation room; (3) Defendant's argument that his detention was extensive and that he was denied prescription medication during detention was waived; and (4) Defendant's argument that the trial justice abused his discretion by failing to suppress a witness's out-of-court identification was also waived. View "State v. Baribault" on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of first-degree sexual assault and three counts of second-degree child molestation after a jury trial, holding that there was no error in the proceedings below.On appeal, Defendant argued that the trial justice clearly erred in denying his motion for a new trial because the justice overlooked and misconstrued material evidence and the weight of the evidence did not support the verdict. The Supreme Court disagreed and affirmed, holding that there was no reversible error in the trial justice's analysis of the motion for a new trial or in his decision denying the motion. View "State v. Acosta" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the superior court confirming the judicial foreclosure of Defendant's home in favor of Plaintiff, Ocwen Loan Servicing, LLC, holding that the superior court did not err.On appeal, Defendant argued that the trial justice erred by confirming the foreclosure sale because she had not been provided a copy of a notice of foreclosure counseling at least forty-five days prior to receiving the certified letter and that Plaintiff foreclosed the property without holding the note or the mortgage. The Supreme Court affirmed, holding (1) the trial justice did not err in confirming the judicial foreclosure sale; and (2) because Plaintiff had been assigned the mortgage prior to the foreclosure sale it did not need to hold the note in order to foreclose on the property. View "Ocwen Loan Servicing, LLC v. Medina" on Justia Law

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The Supreme Court affirmed the judgment of the superior court in favor of Citizens Bank, N.A. arising from two delinquent student loans, holding that the superior court did not err.In 2007, Defendant entered into two separate student loan agreements, one of which Defendant received from Charter One Bank, which later changed its name to Citizens Bank, N.A. In 2007, Citizens Bank filed this action seeking damages for the remaining amount due on the loans. After a hearing, the trial court granted summary judgment in favor of Citizens Bank. The Supreme Court affirmed, holding that Defendant's arguments on appeal were without merit. View "Citizens Bank, N.A. v. Palermo" on Justia Law

Posted in: Banking
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The Supreme Court affirmed the judgment of the superior court confirming an arbitration award in favor of Petitioner, holding that there was no error by the hearing justice in granting the motion to confirm and denying the motion to vacate the award.Respondent filed a negligence action against Petitioner after their automobiles collided. The parties submitted the matter to nonbinding arbitration, and the arbitrator concluded that Respondent failed to satisfy his burden of showing that Petitioner acted negligently. Respondent filed a motion to vacate the arbitration award, and Petitioner filed a separate petition to confirm the arbitration award. The hearing justice confirmed the award. The Supreme Court affirmed, holding that Respondent failed to overcome his burden of defeated the presumption of validity to which an arbitration award was entitled. View "Wiggins v. Pianka" on Justia Law

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The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendants, the individual unit owners of the Goat Island South Condominium (GIS Condominium) and the Goat Island South Condominium Association, Inc. (GISCA), holding that there was no genuine issue of material fact remaining in this case.In his decision, the hearing justice concluded (1) Plaintiff, IDC Clambakes, Inc., had failed to demonstrate that it would be unjust for Defendants to receive any benefit or that it conferred a benefit upon Defendants; and (2) Clambakes' quasi-contract claims were barred by res judicata. The Supreme Court affirmed, holding that Defendants were entitled to judgment as a matter of law because it would be inequitable for Defendants to retain any benefit that may have been conferred on them by Clambakes. View "IDC Clambakes, Inc. v. Carney" on Justia Law

Posted in: Contracts
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The Supreme Court affirmed the judgment of the superior court entered in favor of Plaintiffs, Charles and Nicole Martin, on their claim for injunctive relief allowing them to access a common driveway for the purpose of entering and existing their property and enjoining Defendants, Glenn and Valerie Wilson, from interfering with such use, holding that the trial justice did not err.Specifically, the Supreme Court held that the trial justice (1) did not err by allowing parol evidence to be admitted; (2) neither overlooked nor misconceived material evidence in finding that Plaintiffs established an implied easement over the disputed section of the common driveway; and (3) did not err by finding that Defendants' counterclaims for declaratory judgment, trespass, and equitable relief were moot. View "Martin v. Wilson" on Justia Law