Justia Rhode Island Supreme Court Opinion Summaries

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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

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of two counts of felony assault, holding that the trial justice did not abuse his discretion by permitting the state to impeach Defendant with a prior felony assault conviction.Defendant's first jury trial ended in a mistrial after a hung jury. After a second criminal jury trial before a different trial justice, the jury found Defendant guilty of two counts of assault with a dangerous weapon. On appeal, Defendant argued that the second trial justice abused his discretion by deviating from the law of the case doctrine and allowing a prior felony assault conviction to be introduced for impeachment purposes. The Supreme Court affirmed, holding that, under the circumstances, the trial justice did not abuse his discretion by allowing the State to impeach Defendant's credibility with his prior felony assault conviction. View "State v. Jones" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court in favor of Plaintiff, Bank of America, in this consolidated appeal, holding that the hearing justice did not err.Defendants were the sole principles of an LLC. The LLC executed a promissory note to Plaintiff secured by a first-position mortgage on the property. On the same day, Defendants executed a guaranty of the loan agreement. When the LLC failed to pay the note, Plaintiff filed complaints in Connecticut Superior Court and in Rhode Island Superior Court seeking to foreclose on the property and arguing that Defendants were jointly and severally liable for the indebtedness due under their guaranty. In both actions, final judgment was entered in favor of Plaintiff. The Supreme Court affirmed, holding that the hearing justice did not err when he (1) granted Plaintiff's motion for partial summary judgment as to Defendants' liability on the guaranty; (2) found that Defendants were bound by the Connecticut Superior Court's deficiency calculation; and (3) denied Defendant's motion to amend his answer without holding a hearing. View "Bank of America, N.A. v. Fay" on Justia Law

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The Supreme Court affirmed the order of the superior court dismissing Plaintiff's complaint alleging that Defendant, Rhode Island Public Transit Authority (RIPTA), failed to compensate her for past workplace injuries, holding that the trial justice properly dismissed the complaint.The trial justice found that the superior court did not have jurisdiction over certain claims because they were committed to the Workers' Compensation Court, that Plaintiff did not properly articulate other claims, and that the complaint failed adequately to inform Defendant of the nature of Plaintiff's claims. The Supreme Court affirmed, holding that Plaintiff's claims on appeal were without merit. View "Barnes v. Rhode Island Public Transit Authority" on Justia Law

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The Supreme Court affirmed the judgment of the superior court denying Appellant's administrative appeal from a decision of the Rhode Island Department of Health (DOH) in favor of the DOH director, Board of Examiners in Dentistry of the DOH, and the DOH, holding that the trial justice did not err.The Board imposed sanctions upon Appellant John F. Begg, D.D.S. for violations of R.I. Gen. Laws 5-31.1-10(19), (23), and (24) and sections 25.1.1, 27.1(s), 27.1(x), and 27.1(w) of DOH's rules and regulations pertaining to dentists, dental hygienists, and dental assistants. The trial justice affirmed the Board's decision. The Supreme Court affirmed, holding (1) the DOH had subject matter jurisdiction over the administrative proceedings; (2) the Board did not utilize the subpoena power provided to it by R.I. Gen. Laws 5-31.1-4 and 5-31.1-14 in its request for patient healthcare information, nor was it required to do so; and (3) legally competent evidence existed to support the sanctions imposed by the Board. View "Begg v. Alexander-Scott" on Justia Law

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The Supreme Court affirmed the judgment of the superior court against Plaintiff and in favor of Defendant with respect to claims for fraud, negligent misrepresentation, and unjust enrichment, holding that Plaintiff's appeal was not properly before the Court.Plaintiff's underlying claims seemed from a relationship between Plaintiff and Defendant. Plaintiff asserted that he and Defendant had committed to each other to be in a long-term relationship but that Defendant decided to end that relationship. Plaintiff argued that, but for Defendant's representation that they would remain together, Plaintiff would not have devoted his time, energy, and expertise to Defendant. The superior court granted summary judgment for Defendant on all counts. The Supreme Court affirmed, holding that Plaintiff's appeal was untimely. View "Paroskie v. Rhault" on Justia Law

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The Supreme Court affirmed the judgment of the superior court entering summary judgment against Plaintiff and in favor of Defendants - Michael Baird, Mike's Professional Tree Services, Inc. (MPTS), and John Rossi - with respect to Plaintiff's personal injury claims, holding that the superior court did not err.This litigation arose from a serious injury that Plaintiff suffered while he was engaged as a foreman for a tree removal crew. Plaintiff filed a complaint alleging that Defendants had been negligent on the day of the accident. The central dispute between the parties on summary judgment was whether Plaintiff was employed by MPTS, as Defendants asserted, or whether Plaintiff was an employee of a related but distinct entity, as Plaintiff insisted. The hearing justice determined that MPTS was Plaintiff's employer and granted summary judgment for Defendants. The Supreme Court affirmed, holding that the hearing justice properly determined that Plaintiff was employed by MPTS and correctly granted Defendants' motion for summary judgment. View "Selby v. Baird" on Justia Law

Posted in: Personal Injury
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The Supreme Court affirmed the order of the superior court denying Defendant's motion for a new trial, holding that the motion for a new trial was untimely filed.Defendant was found guilty of sex trafficking of a minor and conspiring to do so and three counts of first-degree sexual assault. The Supreme Court vacated the convictions for sex trafficking of a minor and conspiring to do so and otherwise affirmed. Defendant subsequently filed a second motion for a new trial, arguing that the vacatur of his convictions on counts four and six constituted newly available evidence, allowing him to file this motion. The trial justice denied the motion. The Supreme Court affirmed, holding that the motion for a new trial was filed outside of the ten-day time limit set forth in Rule 33, which cannot be waived. View "State v. Maxie" on Justia Law

Posted in: Criminal Law