Justia Rhode Island Supreme Court Opinion Summaries

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The Supreme Court affirmed Defendant's conviction for six counts of first-degree child molestation sexual assault, three counts of second-degree child molestation sexual assault, and second-degree child abuse, holding that there was no error in the proceedings below.On appeal, Defendant argued among other things, that the trial justice erred in admitting evidence of past bad acts without articulating the special relevance of the evidence in the limiting instructions. The Supreme Court disagreed, holding (1) the trial justice did not overlook or misconceive material evidence in denying Defendant's motion for a new trial; and (2) the trial justice did not err in admitting evidence under Rule 404(b) of the Rhode Island Rules of Evidence because Defendant's objection to the instructions he sought to argue was waived. View "State v. Phillips" on Justia Law

Posted in: Criminal Law
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The Supreme Court vacated Defendant's conviction for assault and battery with a dangerous weapon, leaving the scene of an accident resulting in physical injury, reckless driving resulting in physical injury, and violating a no-contact order, holding that the trial justice erred in instructing the jury, resulting in reversible error.Defendant's conviction arose from a bar fight and its aftermath, when Defendant drove his vehicle into two women and then fled the scene. Three counts arose from violations of a no-contact order. On appeal, Defendant argued, among other things, that the trial justice committed reversible error when he instructed the jury that it was entitled to consider whether he was intoxicated at the time of the incident. The Supreme Court agreed and remanded the case for a new trial, holding (1) the trial justice erred when he instructed the jury that it could consider Defendant's intoxication, and the error required reversal of Defendant's convictions; and (2) the trial justice erred in ruling that two separate counts of violating a no-contact order did not merge. View "State v. Narcovich" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the decision of the Retirement Board of the Employees' Retirement System of the City of Providence denying Petitioner's application for an accidental disability retirement, holding that the Board relied on legally competent evidence.Petitioner, a firefighter, injured his right shoulder while lifting a patient. After he had recovered, he sustained a second work-related injury to his right shoulder. When a doctor evaluation concluded that he could not return to working full duty Petitioner submitted an application for an accidental disability retirement. The Board denied the application. On appeal, Petitioner argued that the Board ignored the legally competent evidence before it when it denied his application for an accidental disability retirement. The Supreme Court disagreed, holding that some evidence supported the Board's decision. View "Starnino v. Employees' Retirement System of City of Providence" on Justia Law

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The Supreme Court affirmed the judgment of the superior court in favor of Defendant in this defamation case, holding that the trial justice did not err by granting summary judgment as a matter of law.The jury returned a verdict in favor of Plaintiff on her slander claim. After the jury verdict was rendered, the trial justice granted Defendant's motion for judgment as a matter of law and, in the alternative, granted Defendant's motions for a new trial and a remittitur. The trial court granted Defendant's motion for judgment as a matter of law pursuant to rule 50 of the Superior Court Rules of Civil Procedure, concluding that Plaintiff failed to present sufficient evidence that Defendant made defamatory statements. The Supreme Court affirmed, holding that Plaintiff failed to prove that Defendant's statements were false or were made with actual malice. View "Fuoco v. Polisena" on Justia Law

Posted in: Personal Injury
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The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendant and dismissing Plaintiffs' claim for breach of the implied warranty of habitability, holding that Plaintiffs' claim for breach of the implied warranty of habitability was time barred.Plaintiffs purchased a home from Defendant and received a warranty deed. Plaintiffs later brought this action alleging seven counts. The hearing justice granted summary judgment in favor of Defendant on all counts, determining that Plaintiffs' tort claims were barred by the statute of repose and that this Court's holding in Nichols v. R.R. Beaufort & Associates, Inc., 727 A.2d 174 (R.I. 1999), barred Plaintiffs' claim based on the implied warranty of habitability. The Supreme Court affirmed, holding (1) Nichols applies to original homeowners, and therefore, homeowners have a period of ten years following substantial completion of improvement to real property to discover a latent defect; and (2) Plaintiffs' claim for breach of the implied warranty of habitability in this case was time barred. View "Mondoux v. Vanghel" on Justia Law

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The Supreme Court affirmed the judgment of the superior court declaring Defendant to be a probation violator and sentencing Defendant to the nine years remaining on his suspended sentence, holding that there was no error or abuse of discretion.On appeal, Defendant argued that the order to serve the nine years remaining on his suspended sentence was improperly based on the new charges alone, without proper attention being given to the original conviction for which he was on probation. The Supreme Court affirmed, holding that the hearing justice acted within her discretion by executing the full nine years of Defendant's original suspended sentence. View "State v. Segrain" on Justia Law

Posted in: Criminal Law
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The Supreme Court vacated the judgment of the superior court convicting Defendant of possession of child pornography and sentencing him to a term of imprisonment of five years, with two years suspended, with probation, holding that the trial justice erred by denying Defendant an opportunity to address the jury with an opening statement.Defendant chose to proceed pro se at trial. Immediately after the State delivered its opening statement, Defendant also sought to offer an opening statement. Following a colloquy, the trial justice refused to allow Defendant to make an opening statement. The Supreme Court vacated the judgment below, holding that the trial justice erred when he did not make a proper inquiry of Defendant before precluding him from making an opening statement to the jury. View "State v. Smith" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the superior court's grant of judgment as matter of law in favor of Defendant, individually and as trustee of The Gilbert F. Roy, Jr. Residence Trust - 2005, holding that the trial justice did not err.Plaintiffs sought a declaratory judgment that Defendant was holding property in a constructive trust for their benefit and asked the superior court to order Defendant to convey a co-tenancy interest to them. Plaintiffs requested monetary damages and asserted claims of promissory estoppel and unjust enrichment. The trial justice granted Defendant's motion for judgment as a matter of law. The Supreme Court affirmed, holding (1) the trial justice did not misapply the law of constructive trusts to the facts; (2) there was no error in the trial justice's finding that Plaintiffs failed to establish a valid promissory estoppel claim; and (3) the trial justice did not err in her analysis of Plaintiffs' unjust enrichment claim. View "Sousa v. Roy" on Justia Law

Posted in: Trusts & Estates
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The Supreme Court affirmed the judgment of the superior court finding Defendant guilty of assault with a dangerous weapon - a shod foot - and driving while intoxicated, holding that the trial justice did not err when she instructed the jury about the concept of aiding and abetting and that Defendant's Frye hearing was not conducted in error.On appeal, Defendant argued that the trial justice erred in charging the jury that it could convict him as either a principal or as an aider and abetter and that the trial justice erred during the Frye hearing because she failed to put him on notice that he was exposed to criminal liability for aiding and abetting. The Supreme Court affirmed, holding (1) an instruction on aiding and abetting was justified by the evidence; and (2) the trial justice did not err in the manner in which she proceeded during the Frye hearing. View "State v. Haffner" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of purchasers of a marina, holding that Plaintiff's claims were barred by the doctrine of res judicata.An earlier partition action was commenced to settle an intrafamily properly dispute among descendants of Eleanor Mott. In that action, a special master, who was appointed to manage the businesses of the various properties subject to partition, terminated Plaintiff's lease to one of those properties, a marina, because a bona fide purchaser had agreed to purchase the various properties during the course of the partition proceeding, in which Plaintiff had participated. Plaintiff then initiated this action to challenge the special master's authority to terminate Plaintiff's lease. The superior court granted summary judgment to the purchasers of the marina, finding that Plaintiff's claims were barred by res judicata. The Supreme Court affirmed, holding that the hearing justice did not err by granting summary judgment for Defendants on res judicata grounds. View "BI Boat Basin Associates, LLC v. Sky Blue Pink, LLC" on Justia Law