Justia Rhode Island Supreme Court Opinion Summaries

A deputy sheriff employed by the Rhode Island Department of Public Safety applied for both ordinary and accidental disability retirement pensions, claiming a back injury sustained in 2011 caused him to stop working in 2020. The Employees’ Retirement System of Rhode Island’s Disability Committee recommended approval of only the ordinary disability pension, finding the accidental disability claim untimely under the statutory filing limits, and noting no evidence of an intervening injury or aggravation. The state retirement board adopted this recommendation and denied the accidental disability pension. Despite submitting additional evidence and requesting rehearing and further medical evaluation, the deputy sheriff’s application continued to be denied by the board, which advised that any appeal could be made in the Superior Court or the Workers’ Compensation Court, if applicable.Following these denials, the deputy sheriff filed appeals in both the Superior Court and the Workers’ Compensation Court. The Employees’ Retirement System moved to dismiss the Workers’ Compensation Court matter, arguing that the court lacked jurisdiction over a state employee’s appeal. The trial judge of the Workers’ Compensation Court denied the motion, concluding that jurisdiction existed based on multiple statutes, including those relating to injured-on-duty payments and the right to appeal denials of accidental disability pensions.The Supreme Court of Rhode Island reviewed the case on certiorari and held that the Workers’ Compensation Court did not have subject matter jurisdiction to hear the deputy sheriff’s appeal. The Court reasoned that the statutory scheme provides for Workers’ Compensation Court jurisdiction only for municipal employees covered under the Optional Retirement Plan, not for state employees like the petitioner, who are covered by the state retirement system. The Supreme Court therefore quashed the trial judge’s order and remanded the case for dismissal due to lack of jurisdiction. View "O'Connell v. Employees' Retirement System of Rhode Island" on Justia Law

The plaintiffs purchased undeveloped property in Westerly, Rhode Island, in 1999. In 2007, they applied to the Rhode Island Department of Environmental Management (DEM) for permission to install an onsite wastewater treatment system (OWTS), a prerequisite for building a residence on their land. DEM denied their application because the groundwater table on the property was only five inches below the surface, while regulations required a minimum of twelve inches. The plaintiffs did not pursue an administrative appeal at that time.In 2020, more than a decade after the denial, the plaintiffs filed suit in Washington County Superior Court, seeking declaratory relief and compensation for an alleged regulatory taking under state and federal law. They also asserted that the regulation violated their rights to equal protection and due process. The state moved to dismiss the action, contending it was time-barred, the plaintiffs failed to exhaust administrative remedies, and they lacked standing. The Superior Court agreed, holding that the claims were barred by the statute of limitations, that administrative remedies had not been exhausted, and that the plaintiffs lacked standing. The court dismissed the case with prejudice.On appeal, the Supreme Court of Rhode Island reviewed whether the lower court’s dismissal was proper. The Court held that the three-year statute of limitations applied to all claims, and the continuing violation doctrine did not toll the limitations period because DEM’s denial of the permit was a discrete act, not a continuing violation. The Court further found the plaintiffs lacked standing for prospective relief because they did not allege an actual or imminent injury, as any future application might not necessarily be denied. The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. View "Majeika v. State of Rhode Island" on Justia Law

A tenured teacher employed by a city was charged with a criminal offense, resulting in his placement on paid administrative leave. Over a year later, while the charge was still pending, the city changed the teacher's status to unpaid suspension. The teacher’s union filed a grievance contesting the unpaid suspension, leading to arbitration, where the arbitrator determined that the city had good and just cause for the suspension without pay. After the criminal charge was dismissed, the city reinstated the teacher. The union then filed a second grievance seeking back pay for the period of unpaid suspension, which both parties agreed to arbitrate.Following this, while the arbitration on the back-pay grievance was still pending, the teacher independently filed an action for declaratory relief in the Providence County Superior Court, seeking a declaration that he was entitled to back pay under the Teachers’ Tenure Act. The city moved to dismiss, arguing that the teacher had already selected the grievance and arbitration process as his remedy. The trial justice granted the motion, citing the election of remedies doctrine and relying on precedent, specifically Martone v. Johnston School Committee, which precludes pursuing multiple remedies for the same dispute when a party has already elected a process under a collective bargaining agreement.The Supreme Court of Rhode Island reviewed the case and affirmed the Superior Court’s dismissal. The Court held that once a party elects to pursue a remedy through the grievance and arbitration procedures in a collective bargaining agreement, they are foreclosed from simultaneously or subsequently seeking judicial relief for the same dispute under the doctrine of election of remedies. The disposition by the Supreme Court of Rhode Island was to affirm the lower court’s judgment. View "Peasley v. City of Providence" on Justia Law

A dispute arose regarding the sale of property located at 301 Harris Avenue in Providence, Rhode Island. The plaintiff, 1100 North Main LLC, sought to purchase property from the Providence Firefighters Realty Corp. (the Firefighters), contingent on the Firefighters acquiring replacement property. The Firefighters entered into negotiations with the defendant, Shoreby Hill Properties, Inc., to purchase the Harris Avenue property. After several communications, the Firefighters signed a draft purchase and sales agreement for the property, but the defendant refused to execute it and reportedly accepted another offer. The plaintiff then filed a complaint seeking declaratory, equitable, or monetary relief based on the alleged contract, and recorded two notices of lis pendens against the Harris Avenue property.In the Providence County Superior Court, the defendant moved to dismiss the complaint, quash the lis pendens, and sought sanctions. The plaintiff argued that the attorneys’ communications constituted assent and that a purported assignment from the Firefighters gave the plaintiff standing. Before the Superior Court justice issued a decision, the plaintiff attempted to amend its complaint to add factual allegations and clarify standing. The trial justice dismissed the complaint and quashed the lis pendens, finding that the allegations failed to satisfy the statute of frauds and did not establish standing. The motion to amend was denied as futile, as no enforceable contract was found.On appeal, the Supreme Court of Rhode Island reviewed whether a binding contract existed under the statute of frauds and whether denial of the motion to amend was proper. The Supreme Court held that the unsigned purchase and sales agreement did not satisfy the statute of frauds and no binding contract existed. The Court affirmed the Superior Court’s dismissal of the complaint, quashing of the lis pendens, and denial of the motion to amend. View "1100 North Main LLC v. Shoreby Hill Properties, Inc." on Justia Law

In 2011, Deutsche Bank filed a breach-of-contract action against Walter M. Potenza and Carmela Natale, alleging default on a promissory note and loan modification agreement. Deutsche Bank obtained a judgment for $1,662,837.12 in 2017. In 2021, the plaintiffs filed an independent action in equity, claiming Deutsche Bank committed fraud on the court by falsely asserting it was the holder of the note, despite knowing the note had not been properly endorsed.The Superior Court granted Deutsche Bank's motion for judgment on the pleadings, finding no credible evidence of fraud and determining that the plaintiffs' failure to obtain the deposition earlier was due to their attorneys' negligence. The plaintiffs appealed this decision.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's decision. The Court held that the plaintiffs could not establish all the elements required for relief under Rule 60(b). Specifically, the plaintiffs admitted Deutsche Bank was the holder of the note in their 2011 answer and did not present evidence or seek a continuance during the 2017 summary judgment hearing. The Court concluded that the plaintiffs' failure to challenge the validity of the note or the knowledge of Deutsche Bank's affiant precluded them from obtaining relief. The judgment in favor of Deutsche Bank was affirmed, and the case was remanded to the Superior Court. View "Potenza v. Deutsche Bank National Trust Company" on Justia Law

Capital Video Corporation (CVC) obtained a judgment against Joseph A. Bevilacqua in 2002 for $178,000 plus interest. CVC requested and received an original execution in December 2002, which lapsed. In 2004, CVC obtained an alias execution, recorded it against property jointly owned by Bevilacqua and his wife, Donna Bevilacqua. In 2005, CVC obtained another alias execution, recorded it against another jointly owned property, and later partially discharged it. In 2020, CVC requested a replacement execution, which was issued and recorded against a property in North Providence. This property was later transferred to Donna Bevilacqua and then to her trust. In 2022, CVC obtained another pluries execution and scheduled a constable’s sale of the property. Donna Bevilacqua intervened, seeking to prevent the sale.The Superior Court invalidated the 2020 and 2022 pluries executions, finding that they were not issued within the six-year limitation period set by § 9-25-3. The court determined that the 2020 execution was not issued within six years of the 2005 alias execution and that the 2022 execution was invalid because it assumed the validity of the 2020 execution.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's decision. The Court held that the 2020 and 2022 pluries executions were invalid because they were not issued within the six-year period required by § 9-25-3. Additionally, CVC failed to properly apply for a replacement execution and did not provide proof that the 2005 alias execution was lost or destroyed. The Court concluded that the trial justice did not err in ordering the release and discharge of the 2020 and 2022 pluries executions. View "Capital Video Corp. v. Bevilacqua" on Justia Law

E.H. Turf Supply Company, Inc. filed a small-claims action against Roger Tavares, alleging that Tavares stopped payment on a check for services performed on his tractor. Tavares denied the allegations and counterclaimed for $2,500, asserting that the services were not rendered. The District Court ruled in favor of E.H. Turf Supply, awarding $1,500 plus costs. Tavares appealed to the Superior Court, arguing procedural errors and bias.The Superior Court held a de novo bench trial. E.H. Turf Supply presented testimony from its president, Erik Hagenstein, who detailed the company's repair process and confirmed that Tavares had approved and paid for the services before stopping payment. Tavares cross-examined Hagenstein and attempted to introduce invoices from other repair shops to show that the repairs were not properly done. The trial justice excluded these invoices as hearsay but allowed Tavares to testify about his experience.The Superior Court found in favor of E.H. Turf Supply, awarding $1,703.71. Tavares appealed to the Rhode Island Supreme Court, arguing that the Superior Court erred in allowing E.H. Turf Supply to present its case first, excluding his evidence, and not considering his status as a self-represented litigant.The Rhode Island Supreme Court reviewed the case and found no merit in Tavares's arguments. The Court held that E.H. Turf Supply, as the plaintiff, was correctly allowed to present its case first. The exclusion of the invoices was proper as they were hearsay, and the trial justice provided Tavares with ample opportunity to present his case. The Court affirmed the judgment of the Superior Court. View "E.H. Turf Supply Co. v. Tavares" on Justia Law

The plaintiffs, Robert and Etleva Stratoberdha, filed a lawsuit in Superior Court against Clements Properties, LLC, Robert P. Rucando, and officials from the Town of Portsmouth. They alleged that Clements Properties caused continuous trespass by creating an illegal drainage structure, Rucando failed to disclose flooding issues when selling the property, and the Town neglected to enforce ordinances. During the prolonged litigation, Etleva filed for divorce, and the Family Court issued orders related to the sale of the marital home and the settlement of the Superior Court action.The Family Court appointed a Commissioner to sell the marital home and authorized her to settle the Superior Court action. Robert did not appeal these orders. The Family Court later approved a settlement agreement where Clements Properties would buy the marital home for $870,000, and the Town would pay $75,000 in damages. The Family Court's orders and the settlement agreement were incorporated into the interlocutory decision pending entry of final judgment in the divorce case. Robert's appeal of this decision was dismissed as untimely.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's order approving the settlement agreement. The Court held that the Family Court's orders were final and could not be challenged in the Superior Court. The Superior Court's approval of the settlement agreement was a ministerial act based on the Family Court's final decrees. The Court found no merit in Robert's arguments and concluded that the Superior Court properly relied on the Family Court's orders. View "Stratoberdhav. Clements Properties, LLC" on Justia Law

In this case, the plaintiffs, Kristina Urbonas and Arunas Aniukstis, purchased property at 5 Bowser Court in Newport, Rhode Island. The defendant, NRI 51 Kingston Partnership (NRI), acquired adjacent property at 51 Kingston Avenue. A dispute arose when NRI's representative, John Gullison, conducted renovations and removed part of the plaintiffs' cobblestone landing, claiming it encroached on NRI's property. Plaintiffs filed a lawsuit seeking a declaration of ownership over the disputed land based on the doctrine of acquiescence, adverse possession, and an easement by prescription.The Superior Court awarded title to the plaintiffs for the disputed land, finding that the plaintiffs had acquired the land through the doctrine of acquiescence. The court also granted title to other abutters of Bowser Court, even though they had not requested such relief. NRI appealed, arguing that the trial justice misapplied the doctrine of acquiescence and erred in awarding title to other abutters.The Rhode Island Supreme Court reviewed the case and found that the trial justice erred in granting relief to the other abutters who had not requested it. The court also determined that the doctrine of acquiescence was not applicable because the disputed boundary was not solely on the parties' adjoining lots but also bordered Bowser Court. However, the court found that the plaintiffs had established an easement by prescription over the five-foot strip of land, as they had used the walkway openly, continuously, and hostilely for the statutory period.The Rhode Island Supreme Court affirmed the Superior Court's judgment in part, recognizing the plaintiffs' easement by prescription, and vacated the part of the judgment granting relief to the other abutters. View "Urbonas v. Gullison" on Justia Law

Jacquelin Glassie filed a claim against the estate of her father, Donelson Glassie, alleging he breached a property settlement agreement by failing to adequately fund a trust established for her benefit. The executor of Donelson's estate, Paul Doucette, disallowed the claim, leading to a lawsuit in the Superior Court. After Jacquelin's death, her sister Alison, as executrix of Jacquelin's estate, continued the lawsuit. The Superior Court initially granted summary judgment for the estate, but the Rhode Island Supreme Court reversed, holding that the trustee of the trust, Wells Fargo, was the proper plaintiff. Wells Fargo then assigned its claims to Alison.A jury trial in the Superior Court resulted in a verdict for Alison, awarding her $1,164,138.43 in damages, which, with prejudgment interest, totaled $2,856,572.45. The jury also rejected the estate's counterclaim that Jacquelin had forfeited her interest under Donelson's will. The defendant, Doucette, filed a notice of appeal but failed to timely order the trial transcripts, leading Alison to move to dismiss the appeal.The Rhode Island Supreme Court reviewed the case after the Superior Court granted Alison's motion to dismiss the appeal due to Doucette's failure to timely order the transcripts and follow proper procedures for an extension. The Supreme Court affirmed the Superior Court's decision, finding no abuse of discretion. The Court emphasized that Doucette's reasons for the delay, including hopes for mediation and cost-saving, did not constitute excusable neglect. The Court noted the extensive litigation history and the trial justice's efforts to move the case forward, concluding that the deadlines were necessary and should be adhered to. View "Glassie v. Doucette" on Justia Law