Justia Rhode Island Supreme Court Opinion Summaries

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

The plaintiff, Noah Gabriel, owns an undeveloped parcel of real estate in Narragansett, Rhode Island. The Coastal Resources Management Council (CRMC) received a notification of potential wetland violations on the property and investigated, finding that the property had been altered by clearing vegetation, applying fill soil, installing a culvert, and expanding a driveway. CRMC issued a cease-and-desist order and later an order to restore the property. Gabriel disputed CRMC's jurisdiction and filed a complaint in Washington County Superior Court, asserting that CRMC lacked jurisdiction and had committed various illegal actions.The Superior Court granted CRMC's motion for a temporary restraining order and preliminary injunction, ordering Gabriel to cease all activities on the property. Gabriel appealed, arguing that CRMC did not have the authority to enforce wetland regulations on his property and cited the Clean Water Act and the Supreme Court decision in Sackett v. Environmental Protection Agency.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's order. The Court found that the hearing justice did not abuse her discretion in granting the preliminary injunction. The Court determined that CRMC had a reasonable likelihood of success on the merits, as there was evidence of wetland violations. The Court also found that CRMC would suffer irreparable harm without the injunction, as continued alterations to the property would harm the environment. The balance of equities favored CRMC, and the issuance of the injunction would preserve the status quo by protecting the wetland. View "Gabriel v. Willis" on Justia Law

The case involves a dispute over a real estate transaction between Francesco Scotti and Matthew Mimiaga concerning a property at 300 Benefit Street in Providence, Rhode Island. In 2015, Scotti sold the property to Mimiaga, who financed the purchase through a promissory note. As part of the transaction, Scotti was granted an option to repurchase the property within five years for $900,000. Scotti claimed he exercised this option by mailing a handwritten letter to Mimiaga on June 1, 2020, but Mimiaga denied receiving it. Scotti also alleged that Mimiaga requested extensions to stay on the property due to COVID-19 and other issues, which he granted.The Superior Court granted summary judgment in favor of Mimiaga, ruling that the option agreement lacked separate consideration, Scotti did not properly exercise the option, and there was no express or implied waiver of the option's terms. The court found no evidence that Mimiaga received the June 1, 2020 letter and concluded that Scotti did not act timely to repurchase the property.The Rhode Island Supreme Court reviewed the case and vacated the Superior Court's judgment. The Supreme Court held that the option agreement was supported by consideration as stated in the written document. It also found that a genuine issue of material fact existed regarding whether Mimiaga received the June 1, 2020 letter, invoking the presumption that mailed notices are received. Additionally, the court determined that whether time was of the essence and whether there was an implied waiver of the option's terms were genuine issues of material fact that precluded summary judgment. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Scotti v. Mimiaga" on Justia Law

The Department of Children, Youth, and Families (DCYF) filed petitions to terminate the parental rights of a father to his three sons, B.M., A.M., and N.M., based on allegations of unfitness. The petitions cited that the children had been in DCYF care for over twelve months without a substantial probability of returning to the father within a reasonable period. The father had moved out of state, inconsistently engaged in required services, and failed to maintain regular visitation with his children. The children were placed in a foster home where they thrived and expressed a desire not to return to their father.The Family Court held a bench trial over several days, admitting various exhibits and hearing testimonies from DCYF caseworkers, therapists, and the father. The court found by clear and convincing evidence that the father was unfit due to his failure to complete required services, inconsistent visitation, and inability to provide a stable environment. The court also found that the children were well-adjusted and bonded with their foster mother, and it was in their best interests to terminate the father's parental rights.The Rhode Island Supreme Court reviewed the case and affirmed the Family Court's decree. The Supreme Court found that there was competent evidence supporting the Family Court's findings of unfitness, DCYF's reasonable efforts to reunify the family, and that termination of parental rights was in the best interests of the children. The Supreme Court noted that the father’s inconsistent engagement with services and visitation, along with the children’s expressed wishes and well-being in their foster home, justified the termination of his parental rights. View "In re B.M." on Justia Law

In August 2014, a gunman entered a barbershop in East Providence, Rhode Island, resulting in the fatal shooting of Yusef A’Vant. Thomas Mosley was implicated in the crime, with key testimony from Evan Watson, who admitted to providing the gun and driving Mosley to and from the scene. Watson testified that Mosley retrieved a loaded revolver from the car's glove compartment before entering the barbershop. Additional testimony from Seth Waters, who was present during the incident, and Rithy Suon, Mosley’s then-girlfriend, further implicated Mosley. Suon testified that Mosley showed her a composite sketch of the suspect and later instructed her to deny recognizing voices on a recording. Michael Drepaul, who recorded a conversation with Mosley, also testified, corroborating Watson’s account.In the first trial, Mosley was convicted of carrying a firearm without a license, discharging a firearm during a crime of violence, and obstruction of justice. The jury deadlocked on the murder and conspiracy charges. The trial justice granted a new trial for the firearm discharge charge but denied it for the other convictions. In the second trial, Mosley was convicted of second-degree murder and discharging a firearm during a crime of violence but acquitted of conspiracy to commit murder. He was sentenced to consecutive life sentences and additional time for being a habitual offender.The Rhode Island Supreme Court reviewed the case and affirmed the judgment of conviction. The court found no error in the trial justice’s decisions, including the denial of motions to suppress evidence, the admission of Google Wi-Fi data, and the joinder of charges. The court also rejected Mosley’s claims of double jeopardy, improper jury instructions, and alleged violations of his rights during the trial. The court concluded that the trial justice had acted within his discretion and that the evidence supported the jury’s verdicts. View "State v. Mosley" on Justia Law

The plaintiffs, Jason Blouin and Heather Blouin, filed a medical malpractice lawsuit against several healthcare providers, alleging negligence in the births of their children, X.B. and D.B., who were born with cystic fibrosis. Heather Blouin received prenatal care from University OB-GYN, but was not offered genetic screening or counseling. X.B. was born in 2009 and later exhibited symptoms of cystic fibrosis, but was not diagnosed until 2013. D.B. was born in 2012 and was diagnosed with cystic fibrosis shortly after birth. The plaintiffs claimed that the healthcare providers' failure to diagnose and inform them of the genetic risks led to the births of X.B. and D.B. with cystic fibrosis.The Superior Court granted summary judgment in favor of the pediatric defendants, ruling that they did not owe a duty of care to the parents. The court also granted partial summary judgment in favor of the obstetric defendants, dismissing the wrongful-life claims based on the Rhode Island Supreme Court's decision in Ho-Rath v. Corning Incorporated, which held that no duty is owed to a child born with defects due to negligence in genetic counseling.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's decision. The Court held that the pediatric defendants did not owe a duty to the parents to diagnose X.B. with cystic fibrosis for the purpose of informing their reproductive decisions. The Court also upheld the dismissal of the wrongful-life claims, reiterating that life with impairments does not constitute a legally recognized injury under Ho-Rath III. The Court concluded that the trial justice correctly applied the law and that the plaintiffs' claims failed as a matter of law. View "Blouin v. Koster" on Justia Law

The case involves the divorce of Jose A. Saldana and Daisy M. DeJesus, who married in 2004 and separated in 2009. During their marriage, Saldana purchased a home on Whitmarsh Street, which was later transferred to include DeJesus on the title. After their separation, DeJesus moved to Pennsylvania and later returned to Rhode Island, purchasing another property on Atwells Avenue with her mother. DeJesus filed for divorce in 2018, and the Family Court awarded her the Whitmarsh property, while Saldana retained his pension.The Family Court granted the divorce on grounds of irreconcilable differences and divided the couple's assets accordingly. Saldana did not appeal the final judgment. Later, DeJesus filed a motion to hold Saldana in contempt for not cooperating with refinancing the Whitmarsh property. Saldana filed a motion to vacate the final judgment, arguing that it did not reflect their agreement and that DeJesus had not disclosed all her assets. The Family Court magistrate denied this motion, and Saldana did not appeal.Saldana then filed a second motion to vacate, which was partially granted regarding the Atwells property but denied concerning the Whitmarsh property. The Family Court justice upheld the magistrate's decision, and Saldana appealed to the Rhode Island Supreme Court. The Supreme Court affirmed the Family Court's order, noting that Saldana's second motion to vacate was untimely and should have been dismissed. The issue of the Atwells property remains pending for further proceedings. View "DeJesus v. Saldana" on Justia Law

The case involves a petitioner who filed a miscellaneous petition in Family Court concerning a child whose parents are the respondent and the late Christine Hasselbrock. The petitioner, who had a long-standing platonic relationship with Ms. Hasselbrock, provided financial and emotional support to her and her child. After Ms. Hasselbrock's death, the petitioner sought to be declared a de facto parent or to have other parental rights recognized, but the respondent denied him access to the child.Initially, the petitioner filed an amended verified petition in Family Court, asserting both statutory and common law claims for de facto parentage. The first hearing justice dismissed the statutory claim due to lack of standing, as the petitioner had never resided with the child. The justice indicated that the petitioner could pursue his common law claims on the miscellaneous calendar. Consequently, the petitioner filed a new miscellaneous petition asserting various common law claims, including de facto parentage, in loco parentis, and visitation rights.The Rhode Island Supreme Court reviewed the case and affirmed the Family Court's orders. The Court held that the Rhode Island Uniform Parentage Act (UPA) supersedes common law de facto parentage claims, as the statute explicitly outlines the criteria for establishing de facto parentage. The Court also found that the petitioner lacked standing to pursue claims for visitation based on being an "unrelated caregiver" or "de facto relative," as there is no statutory authority granting such rights. Additionally, the Court affirmed the denial of the respondent's motion for attorneys' fees, finding no basis for such an award. View "De Vries v. Gaudiana" on Justia Law

The Department of Children, Youth, and Families (DCYF) became involved with A.N.'s family after the Rhode Island State Police informed them that A.N.'s father, Francis N., had been arrested on felony charges, including indecent solicitation of a child and electronically disseminating indecent material to a minor. Following his arrest, DCYF initiated an investigation and found that Francis had admitted to soliciting sex from a fictitious 13-year-old girl online. Consequently, DCYF filed a neglect petition against Francis, alleging that he failed to provide A.N. with proper care and supervision.The Family Court granted DCYF temporary custody of A.N. and later held a permanency hearing, ordering that A.N. remain in DCYF's care. Despite DCYF's efforts to engage Francis in services and case planning, he refused to comply, including declining to submit to a sex offender evaluation. During the neglect petition hearing, Francis invoked his Fifth Amendment right against self-incrimination multiple times when questioned about his criminal charges and his involvement with A.N. The Family Court found by clear and convincing evidence that Francis neglected A.N., citing his failure to provide care, supervision, or guardianship, and his lack of engagement with DCYF.The Rhode Island Supreme Court reviewed the case and affirmed the Family Court's decree. The Supreme Court held that it was proper for the Family Court to draw adverse inferences from Francis's invocation of his Fifth Amendment right in a civil proceeding. The Court found clear and convincing evidence supporting the Family Court's finding of neglect, noting Francis's refusal to engage in necessary services, his lack of financial support for A.N., and his displacement of A.N. from the family home. The Supreme Court concluded that Francis's actions demonstrated a disregard for A.N.'s safety and needs. View "In re A.N." on Justia Law

The plaintiffs, Louis Paolino and Marie E. Issa, own property in Cumberland, Rhode Island, adjacent to a site operated as an automobile recycling business. The neighboring property, owned by J.F. Realty, LLC and operated by LKQ Route 16 Used Auto Parts, Inc., was found to be contaminated. The Department of Environmental Management (DEM) required remediation, leading the defendants, Commonwealth Engineers & Consulting, Inc., to design a stormwater remediation system. Plaintiffs alleged that this system discharged contaminated water onto their property and encroached on it.In prior litigation, the plaintiffs sued the Ferreira defendants in state court for trespass due to contamination. The case was removed to federal court, where federal claims were dismissed, and state claims were remanded. A jury found encroachment but awarded only nominal damages. The plaintiffs sought injunctive relief, which was partially granted. On appeal, the Rhode Island Supreme Court affirmed the denial of injunctive relief for the encroachment, deeming it de minimis, but ordered a new trial on other issues. In a subsequent trial, the jury found no continuing trespass. Plaintiffs also pursued a Clean Water Act claim in federal court, which was dismissed after a bench trial.The Rhode Island Supreme Court reviewed the Superior Court's grant of summary judgment in favor of Commonwealth. The court affirmed the judgment, holding that the issues in the current case were precluded by collateral estoppel. The court found that the issue of contamination had been litigated and decided in prior state and federal actions, and the encroachment was previously determined to be de minimis. Thus, the plaintiffs were barred from relitigating these issues. View "Paolino v. Commonwealth Engineers & Consulting, Inc." on Justia Law