Justia Rhode Island Supreme Court Opinion Summaries

A nonprofit healthcare organization, which operates numerous facilities in Providence and one property in Warwick, acquired the Warwick property in 2020. The Warwick site is used primarily for administrative functions and virtual patient services. The organization treats a large number of low-income patients, but not exclusively, as some patients may have higher incomes. In 2021, the Rhode Island General Assembly enacted a statute that exempts from property tax “real and tangible personal property of [the nonprofit], a Rhode Island domestic nonprofit corporation, located in Providence, Rhode Island.” The organization applied to the Warwick tax assessor for an exemption based on this statute and an alternate general exemption for entities serving the poor. The Warwick tax assessor denied the request, concluding the statutory exemption applied only to properties in Providence.The organization appealed to the Warwick Tax Board of Review, which also denied the exemption. It then filed an appeal in the Kent County Superior Court, asserting both the specific and general exemptions applied to its Warwick property. The Superior Court granted summary judgment for the tax assessor, finding the statutes unambiguous and holding the property was not exempt because it was not located in Providence, and because the organization did not exclusively serve the poor.On appeal, the Supreme Court of Rhode Island reviewed the summary judgment de novo. The Court held that the specific statutory exemption only applies to properties owned by the nonprofit in Providence, not Warwick. Additionally, the general exemption for entities aiding the poor requires exclusive service to the poor, which the nonprofit does not meet. The Court affirmed the Superior Court’s judgment, ruling the Warwick property is not exempt from taxation under either statute. View "The Providence Community Health Centers, Inc. v. Dupuis" on Justia Law

This case concerns a dispute between neighboring property owners in Johnston, Rhode Island. The plaintiffs purchased their property in 1985 and, over the years, cleared and improved a strip of land beside their home, installing features such as a playset, landscaping, and a staging area. The disputed strip lay between their property and the defendant’s property. The defendant bought his property in 2011. In 2013, a survey commissioned by the defendant revealed that some of the plaintiffs’ improvements encroached on the defendant’s land. Tensions escalated, leading to the defendant installing a fence and the plaintiffs filing an action to quiet title based on adverse possession, claiming they had possessed the disputed area for the required statutory period.Proceedings in the Providence County Superior Court included a bench trial, where the main factual dispute centered on whether the plaintiffs’ use of the disputed land was “hostile”—that is, without the permission of the record owner. The trial justice found that the plaintiffs had proved adverse possession by clear and convincing evidence as to a portion of the disputed area beyond an old line of hemlock trees, but not as to the area along the tree line itself. The court found the plaintiffs’ claim to hostility was undermined by evidence that a prior owner may have given them permission to use that area. Final judgment was entered, granting partial relief to each party. Both sides appealed.The Supreme Court of Rhode Island affirmed in part and vacated in part the judgment below. The Court held that, contrary to the trial justice’s view, the sale of the servient parcel (i.e., the land that was allegedly permissively used) can terminate prior permission and may render subsequent use hostile for adverse possession purposes. The Supreme Court remanded the case for further factual findings on hostility under the correct legal standard and for clarification on the precise location of the disputed area beyond the hemlock tree line. View "Desrochers v. Micheli" on Justia Law

The case centers on an owner of a waterfront condominium in Newport, Rhode Island, who hired a real estate agency and its agent to find a suitable tenant for his property. The agency presented a candidate, Cynthia Dziurgot, who passed credit and criminal background checks, and the owner entered into a lease with her. After several months, Dziurgot stopped paying rent and refused to vacate the property at the end of the lease, leading to an extended eviction process during the COVID-19 eviction moratorium. The owner later discovered that an internet search would have revealed a history of misconduct and legal issues involving the tenant.The plaintiff filed suit in Newport County Superior Court, alleging breach of contract and negligence by the agency and its agent for allegedly failing to adequately vet the tenant. The plaintiff intended to call a real estate expert to testify that a reasonable real estate professional would have conducted an internet search of the prospective tenant. However, after failing to produce the expert for deposition as agreed in a consent order, the court precluded the plaintiff from offering any expert testimony. The defendants then moved for summary judgment, arguing that without expert testimony, the plaintiff could not establish the applicable standard of care for real estate professionals. The Superior Court granted summary judgment for the defendants, finding that the standard of care was not within common knowledge and required expert testimony.On appeal, the Supreme Court of Rhode Island reviewed the grant of summary judgment de novo. The Court held that establishing the standard of care for real estate professionals regarding background searches is not within the common knowledge of laypersons and requires expert testimony. Because the plaintiff was precluded from offering such testimony, summary judgment for the defendants was affirmed. View "Hurd v. H & H Real Estate, LLC" on Justia Law

In March 2010, a motor vehicle accident occurred on Interstate 95 South in Cranston, Rhode Island, involving Julie DeOliveira, her daughter Maxine, and a truck driven by Greg Trecaso, who was insured by Star Insurance Company. Julie and Maxine claimed that Mr. Trecaso negligently operated his truck, causing their injuries. After Mr. Trecaso and his business were dismissed from the case due to lack of service, Star Insurance remained as defendant. The case proceeded to a jury trial where the key dispute was whether Mr. Trecaso’s actions caused the accident, as described by conflicting accounts from Julie, Maxine, Mr. Trecaso (via deposition), and a police officer.The Providence County Superior Court admitted contested evidence, including Mr. Trecaso’s deposition and a police report, over plaintiffs’ objections. During trial, the jury heard testimony from the plaintiffs, Mr. Trecaso’s deposition, and Trooper Hanley, who investigated the accident. The jury found that neither Julie nor Maxine proved by a preponderance of evidence that Star Insurance’s insured was negligent. Plaintiffs’ motion for a new trial was denied by the Superior Court, as was Star’s motion for judgment as a matter of law.On appeal, the Supreme Court of Rhode Island reviewed several alleged errors, including evidentiary rulings, jury instructions, statements by defense counsel, and the verdict sheet. The Court applied an abuse of discretion standard to evidentiary and procedural rulings and found no error by the trial justice. The Court concluded that the jury instructions were proper, the verdict sheet was not misleading, and the empty chair doctrine was not violated. The Supreme Court affirmed the denial of the plaintiffs’ motion for a new trial and the judgment in favor of Star Insurance Company, declining to address the defendant’s cross-appeal. View "DeOliveira v. Trecaso" on Justia Law

A man was convicted of two counts of first-degree child molestation based on events that began in 2005, when the complainant was ten years old. The complainant, who lived with her mother, became acquainted with the defendant through her older sister and neighbors. After the defendant briefly lived with the complainant’s mother and had a short romantic relationship with her, the defendant and the complainant began spending time together. Their interactions gradually became more physical, progressing to frequent sexual activity, including digital and penile-vaginal penetration, while the complainant was still under fourteen years old. These acts occurred both while the complainant’s mother was at home and during times when she was absent, such as a week-long hospital stay.After several years and a disclosure to her mother and others, the complainant’s allegations were reported to the Rhode Island State Police. The defendant was interviewed by detectives at police headquarters. During the interview, after being informed of his Miranda rights, the defendant invoked his right to counsel, and questioning ceased. However, outside the station, the defendant initiated further conversation with the detective, during which he made incriminating statements. The defendant was later indicted in 2016 after earlier grand jury proceedings did not result in charges.The Rhode Island Superior Court denied the defendant’s motion to suppress his statements to police, finding he was not in custody outside the station and that, even if he had been, he reinitiated contact and knowingly waived his rights. The court also denied his motion for judgment of acquittal, determining that the complainant’s testimony sufficiently established penetration within the charged timeframes.The Supreme Court of Rhode Island affirmed the Superior Court’s judgment. The court held that the trial justice did not err in denying the motion to suppress, as the defendant reinitiated contact and voluntarily waived his rights. The court also upheld the denial of the motion for judgment of acquittal, finding the evidence was sufficient for a reasonable juror to convict. View "State v. Carreiro" on Justia Law

A juvenile was charged in Newport County Family Court with two counts of first-degree child molestation, based on sexual acts he engaged in with a minor who was twelve years old at the time. Prior to trial, a competency hearing was held. Two experts in forensic psychology evaluated the respondent and testified that he had limited understanding of the legal process, particularly about sex offender registration, plea bargains, and the role of the prosecutor. Their report concluded that he did not sufficiently demonstrate factual or rational understanding or adequate decision-making abilities. However, the respondent had no prior mental health diagnoses, cognitive impairments, or psychiatric history.The Family Court judge considered the expert testimony and report but concluded that the respondent’s answers, while imperfect, demonstrated a sufficient understanding of the proceedings and the ability to assist in his defense. The judge found the respondent competent to stand trial. Following a bench trial, the respondent was found delinquent on both counts beyond a reasonable doubt. At sentencing, an expert social worker recommended against sex offender registration, describing the respondent as non-predatory and not a danger to the community. The judge rejected this recommendation, citing deficiencies in the expert’s knowledge of the case facts and the circumstances of the offenses.On appeal, the Supreme Court of Rhode Island reviewed the Family Court’s findings. The Court held that the trial justice did not abuse her discretion in finding the respondent competent, as the trial judge is the ultimate factfinder on competency and need not accept uncontradicted expert testimony. The Court also held that the trial justice did not err or abuse her discretion in imposing the full fifteen-year sex offender registration period, finding the respondent’s conduct was criminal not solely because of the victim’s age but also because of his actions. The orders of the Family Court were affirmed. View "In re E.G.S" on Justia Law

A school committee in a Rhode Island town responded to community members’ concerns about racial inequity in district policies and staff diversity by voting to create an advisory group, later called the BIPOC Advisory Board. This Board was facilitated by a third-party organization under contract with the committee, with meetings initially open only to those identifying as BIPOC. The Board’s role was to discuss and make suggestions about district policies, which it conveyed to a policy sub-committee that, in turn, could submit proposals to the school committee. The Board had no authority to make binding decisions or directly implement policy changes. The school committee funded the facilitation of the meetings but did not compensate Board members.After being denied access to Board meetings, a plaintiff filed a complaint with the Rhode Island Office of the Attorney General, arguing that the Board was a public body subject to the Open Meetings Act (OMA). The Attorney General found that the Board was not a public body under the OMA. The plaintiff then filed suit in the Providence County Superior Court, seeking declaratory relief. The Superior Court denied the plaintiff’s motion for summary judgment and granted summary judgment to the school committee, finding that the Board was not a public body under the OMA. The court reasoned that the Board had no voting or veto power and that the policy review process provided public opportunities for input.On appeal, the Supreme Court of Rhode Island affirmed the Superior Court’s judgment. The Court held that the Board was not a public body subject to the OMA because it was an amorphous, ad hoc advocacy group without authority to make or veto policy decisions. The Court emphasized that the Board’s informal structure, lack of consistent membership, and merely advisory role did not trigger open meetings requirements under Rhode Island law. View "Solas v. South Kingstown School Committee" on Justia Law

After the death of Harry Fairhurst in 2019, his will—executed in 1981 with a 1997 codicil—left his estate equally to his seven children and named two of them as co-executors. The main asset was the family home. The will allowed the co-executors to sell estate assets without probate court approval, provided all children were notified by mail of their option to purchase. In 2020, the co-executors notified the devisees that the property was available, but the letter omitted key sale terms. No child responded. Subsequently, William, one of the co-executors, purchased the property for $260,000, using part of his share as an advance toward the purchase price, despite a higher bank appraisal and market analysis.Three siblings objected to the accounting of the sale in Cumberland Probate Court, focusing on the valuation and terms. The probate court, without hearing argument, found the sale invalid and illegal because the co-executors had not sought probate court approval, as required by Rhode Island General Laws § 33-19-9. The property was ordered to remain with the estate. The co-executors appealed to Providence County Superior Court, arguing the will authorized the sale without court approval and that the probate court’s sua sponte action violated their due process rights. Both sides moved for summary judgment.The Supreme Court of Rhode Island reviewed the case on appeal. It held that, regardless of the will’s language, § 33-19-9 required probate court approval for a co-executor’s private purchase of estate property to prevent self-dealing and ensure fairness. The Court found the will’s contrary provision invalid to the extent it conflicted with the statute and rejected the co-executors’ due process and laches arguments. The Supreme Court affirmed the Superior Court’s judgment, upholding the voiding of the sale. View "Fairhurst v. Fairhurst" on Justia Law

A dispute arose following a failed real estate transaction involving the sale of a hotel property in Warwick, Rhode Island. The property was to be sold by Shiva, LLC, of which Jay Patel was the registered agent, to LandingPartners LLC under a Purchase and Sale and Discounted Pay-Off Agreement. Centreville Bank held a mortgage on the property, which was in default. When Shiva, Airport Hospitality (another entity linked to Patel), and Patel failed to respond to an earlier lawsuit brought by LandingPartners, the Superior Court entered a default judgment against them, ordering specific performance of their obligations under the agreement and appointing a commissioner to facilitate the closing. Afterward, LandingPartners and Centreville Bank reached a consent order with new terms for the sale and discharged the mortgage, and the case was dismissed with prejudice.Shortly after the dismissal of the first case, Patel filed a new lawsuit in the Washington County Superior Court against LandingPartners, Centreville, and a related entity, 1850 Post Road Owner LLC. He alleged violations of the agreement, fraud, misrepresentation, unjust enrichment, and breach of the implied covenant of good faith and fair dealing. The defendants moved to dismiss, arguing the claims were barred by res judicata because they arose from the same transaction addressed in the prior litigation. The Superior Court agreed, finding that the parties or their privies were the same, the issues arose from the same transaction, and there was a final judgment in the first action.The Supreme Court of Rhode Island affirmed the Superior Court’s judgment. The Court held that res judicata barred Patel’s claims, as all issues now raised were or could have been raised in the initial suit, and the new claims concerned the same transaction. The dismissal of Patel’s complaint with prejudice was therefore upheld. View "Jay Patel v. LandingPartners LLC et al." on Justia Law

An employee who worked for a state agency in Rhode Island and regularly used her own personal vehicle for job-related travel was injured in a car accident caused by an underinsured driver. On the day of the incident, no state-owned vehicle was available, so she drove her own car. Her employer, the State of Rhode Island, carried a commercial auto insurance policy with Travelers Property Casualty Company of America, which provided liability coverage for employees using any vehicle within the scope of employment but only provided uninsured/underinsured motorist (UM/UIM) coverage when employees were occupying state-owned vehicles.After the accident, the employee sought UM/UIM benefits from Travelers, but her claim was denied because she was not occupying a covered auto under the policy. She brought suit in Providence County Superior Court, alleging breach of contract, seeking declaratory judgments on coverage, and pursuing bad faith and punitive damages. Travelers removed the case to federal court. The United States District Court for the District of Rhode Island granted summary judgment to Travelers, finding the policy language unambiguously did not provide the coverage she sought, and that Rhode Island law did not otherwise require it.On appeal, the United States Court of Appeals for the First Circuit certified two questions to the Supreme Court of Rhode Island: whether, under Rhode Island law and the precedent of Martinelli v. Travelers Insurance Companies, an employee using her own car within the scope of employment must be considered a named insured for UM/UIM coverage despite contrary policy terms; and whether it violates the Rhode Island Uninsured Motorist Statute or public policy for an employer’s policy to provide liability but not UM/UIM coverage in these circumstances.The Supreme Court of Rhode Island answered both questions in the negative, holding that neither the Martinelli precedent nor Rhode Island law required the employee to be treated as a named insured, and that the statutory and public policy requirements were not violated by the policy’s terms. View "Roberge v. Travelers Property Casualty Company of America" on Justia Law