Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendant in this personal injury action, holding that Plaintiff failed to establish the existence of a legal duty on the part of Defendant.Plaintiff purchased fish at Defendant's supermarket and allegedly became ill after he ate the fish. Plaintiff brought this negligence action alleging that Defendant breached its alleged duty to him to "process, prepare, cook and sell food free from unreasonably dangerous defects." The hearing justice granted summary judgment for Defendant. The Supreme Court affirmed, holding (1) there was no error in the hearing justice's ruling as regarding Defendant's duty; and (2) the hearing justice did not commit reversible error by denying Plaintiff's motion invoking Rule 56(f) of the Superior Court Rules of Civil Procedure. View "Meeks v. Stop & Shop Supermarket Co., LLC" on Justia Law

In these two consolidated cases, the Supreme Court vacated the final judgment granting Respondent the right to redeem its real property in a tax-sale action and from an order granting Respondent's motion to adjudge Petitioner in contempt, holding that there was no offer to redeem to satisfy the strict statutory requirements of R.I. Gen. Laws 44-9-29.After the property at issue, which was owned by Respondent, was sold at a tax sale by the City of Providence Petitioner filed a petition to foreclose on Respondent's right of redemption. Respondent answered by contesting the validity of the tax sale. Respondent then filed a motion to set a redemption figure. The hearing justice set the redemption amount at $65,000. Petitioner failed to deliver the redemption deed, after which Respondent moved to adjudge Petitioner in contempt. The superior court adjudged Petitioner in contempt and granted a motion to stay the order setting a redemption figure. The Supreme Court vacated the final judgment granting Respondent's right of redemption and the order of contempt, holding that, having failed to set forth in its answer an offer to redeem before the fixed return date, Respondent's right to redeem was barred. View "Westconnaug Recovery Co. v. U.S. Bank National Ass'n" on Justia Law

The Supreme Court affirmed the judgment of the trial court deciding to grant Defendant's request to represent himself and denying his motion for a new trial, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that his waiver of his right to the assistance of counsel was not valid and that the trial justice erred when she denied his motion for a new trial. The Supreme Judicial Court affirmed, holding (1) there was no error in the trial justice's decision allowing Defendant to discharge his attorney when and as he did; and (2) the record established that Defendant made a voluntary, knowing, and intelligent waiver of his right to the assistance of counsel; and (3) the trial justice did not err in denying Defendant's motion for a new trial. View "State v. Delossantos" on Justia Law

The Supreme Court affirmed the orders of the superior court in these three related by unconsolidated appeals, holding that Appellants were not entitled to relief on their arguments on appeal.In No. 2021-303-A and No. 2021-331-A, defendants Thomas and John Mercurio appealed pro se from a superior court granting the motion to adjudge the Mercurios in contempt filed by plaintiffs Dean and Melissa Pinelli. In No. 2021-331-A, plaintiff Elena Massarone appealed pro se from a superior court order granting the Pinellis' motion to adjudge Elena in civil contempt. On appeal, Elena and the Mercurios both asserted largely identical claims of error. The Supreme Court affirmed in all cases, holding that because none of the appellants provided transcripts to the Court from any of the hearings held throughout the proceedings and because their statements failed to provide any cogent legal analysis or substantive discussion of their claims, the appellants waived their arguments on appeal. View "Pinelli v. Mercurio" on Justia Law

The Supreme Court set aside the decision of the Rhode Island Office of the Attorney General denying Appellant's application to renew his concealed or open-carry license pursuant to R.I. Gen. Laws ch. 11-47-18(a), holding that the Attorney General's decision was not based on legally competent evidence.Police officers arrested Appellant for misdemeanor simple assault after an incident involving Appellant's firearm at his place of business. Based on this charge, the Attorney General revoked Appellant's license to carry concealed weapons. While the government eventually dismissed the charge against him Appellant's subsequent application to renew his concealed-carry license was denied by the Attorney General. The Supreme Court remanded the case, holding that there was no legally competent evidence to support the Attorney General's decision. View "Montaquila v. Neronha" on Justia Law

In this slip-and-fall case, the Supreme Court affirmed the judgment of the superior court denying Plaintiff's motion for a new trial following a jury verdict in favor of Defendants, holding that the trial justice did not err in denying the motion.Plaintiff sued the Town of Johnson and some of its officials, alleging that Defendants were negligent in maintaining the premises of the Johnston Town Hall in a safe condition by failing to warn invitees, such as himself, of a "dangerous condition" - namely, curbing that lacked any yellow highlighting or warning. The jury returned a verdict for Defendants. Plaintiff filed a motion for a new trial, which the trial justice denied. The Supreme Court affirmed, holding that the trial justice (1) did not err in instructing the jury as to the element of duty; (2) Defendant waived his second claim of instructional error; and (3) the trial justice did not err by concluding that expert testimony was required to establish that the angle of the curb constituted a dangerous condition. View "Mangiarelli v. Town of Johnston" on Justia Law

The Supreme Court dismissed the Episcopal Diocese or Rhode Island's challenge to an order of the Rhode Island Public Utilities Commission (PUC) that permitted the Narragansett Electric Company to charge the diocese for electricity transmission costs associated with a proposed solar development project on diocese property in Glocester, holding that the matter was moot.On appeal, the diocese argued that the PUC's order was unlawful and unreasonable for several reasons, including the assertion that the PUC subjected the diocese to a biased proceeding in violation of state law. After the Supreme Court remanded the matter to the PUC for consideration of newly discovered evidence Narragansett determined that the diocese was not subject to the challenged interconnection costs. The Supreme Court declined to address the merits of the diocese's appeal, holding that the matter was moot. View "In re Petition of the Episcopal Diocese of R.I. for Declaratory Judgment" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting partial summary judgment in favor of Plaintiff in this foreclosure case, holding that there was no error in the proceedings below.Defendant signed a promissory note in favor of Plaintiff that consolidated numerous debts that Defendant owed Plaintiff in connection with various joint real estate projects. The promissory note was secured by a mortgage on certain real estate. When Defendant did not respond to a notice of default and demand for payment under the promissory note Plaintiff brought this action seeking injunctive relief and damages. Eventually, a second hearing justice granted Plaintiff's motion for partial summary judgment on counts one and two of her six-count complaint. The Supreme Court affirmed, holding that the second hearing justice properly applied the law of the case doctrine when granting Plaintiff's motion for partial summary judgment. View "DiMaggio v. Tucker" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Defendant, in her capacity as the Town of Lincoln's tax assessor, holding that Plaintiff was not entitled to relief on its claims of error.Plaintiff brought this action arguing that Defendant (1) illegally increased the value of Plaintiff's property in light of a solar energy development on a portion of Plaintiff's property for tax years 2019 and 2020, and (2) improperly created a new tax classification not recognized by R.I. Gen. Laws 44-5-11.8(b). The superior court granted judgment in favor of Defendant. The Supreme Court affirmed, holding (1) there was no error in including the presence of a solar energy development as an element of value assessed to real property; and (2) Plaintiff's claim that the tax assessor effectively created a new tax classification for property upon which a solar energy development is located, in contravention of R.I. Gen. Laws 44-5-11.8(b), was unpersuasive. View "Polseno Properties Management, LLC v. Keeble" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Plaintiff, Key Corporation, holding that Defendant, Greenville Public Library, was not entitled to relief on its two claims of error.Plaintiff filed a complaint seeing a declaratory judgment that Defendant violated the Access to Public Records Act (the APRA), R.I. Gen. Laws 1956 chapter 2 of title 38, and seeking an order directing Defendant to produce requested records pursuant to the APRA. Plaintiff argued that Defendant was a quasi-municipal corporation that received seventy percent of its funding from the Town of Smithfield and therefore was a "public body" or "agency" as defined by the APRA. The hearing justice determined that Defendant was a public body subject to the APRA and accordingly granted Plaintiff's motion for partial summary judgment. The Supreme Court affirmed, holding that the hearing justice (1) did not err in determining that Defendant was a public body; and (2) acted within his discretion in awarding fees and costs. View "Key Corp. v. Greenville Public Library" on Justia Law