Justia Rhode Island Supreme Court Opinion Summaries

Articles Posted in Civil Procedure
by
The Supreme Court affirmed the order of the superior court dismissing Plaintiff's claims against Defendants seeking a declaratory judgment concerning the propriety of the foreclosure of Plaintiff's property, holding that the superior court did not err. Plaintiff named as defendants Residential Credit Solutions, Inc.; FV REO I, LLC; Franklin Venture, LLC; and DLJ Mortgage Capital, Inc. As part of her complaint, Plaintiff sought to quiet title concerning the property at issue and an award of punitive damages, attorneys' fees, and costs. The hearing justice dismissed Plaintiff's complaint for failure to serve all indispensable parties. The Supreme Court affirmed, holding that Plaintiff's failure to meaningfully discuss the issues raised on appeal was fatal to Plaintiff's appeal. View "Osifodurin v. Residential Credit Solutions, Inc., et al." on Justia Law

by
The Supreme Court affirmed the judgment of the superior court concluding that the superior court is not vested with the inherent supervisory authority to order the public disclosure of grand jury materials that could potentially be reopened and that dealt with events for which the potentially relevant statute of limitations has not yet run, holding that the superior court does not have the authority to disclose grand jury material outside of Rule 6(e)(3) of the Superior Court Rules of Criminal Procedure. A statewide grand jury convened to investigate the possibility of potential criminality in connection with a government deal gone bad (the 38 Studios deal). The investigation concluded with an announcement that there were no provable criminal violations in connection with the deal. In a separate action, the State initiated civil litigation against individuals and entities involved in the 38 Studios deal, and settlements followed. Thereafter, the Governor filed a miscellaneous petition seeking release of the 38 Studios grand jury records, arguing that the superior court has the discretion to release grand jury materials. The superior court denied the petition. The Supreme Court affirmed, holding that the superior court does not have inherent authority to disclose grand jury materials beyond the parameters of the permitted disclosures set forth in Rule 6(e). View "In re 38 Studios Grand Jury" on Justia Law

Posted in: Civil Procedure
by
The Supreme Court affirmed the judgment of the superior court granting Plaintiffs' request for declaratory and injunctive relief and ruling that the Town of Barrington lacked authority under its Home Rule Charter to enact an ordinance banning the sale of flavored tobacco products and prohibiting the providing of any tobacco products to persons under the age of twenty-one (the Tobacco Ordinance), holding that the Town lacked the authority to enact the Tobacco Ordinance. Specifically, the Court held that, while the Tobacco Ordinance was enacted to protect public health and safety, the ordinance constituted legislation concerning a matter of statewide concern, and therefore, it fringed upon the power of the state. Further, because the Town lacked the authority under its Home Rule Charter to enact the ordinance, the hearing justice did not err in declining to decide whether the ordinance was preempted by state law. View "K&W Automotive, LLC v. Town of Barrington" on Justia Law

by
The Supreme Court quashed the order of the district court denying Appellant's motion to seal his records under R.I. Gen. Laws 12-1-12 on the grounds that because Defendant was charged with a civil violation rather than a criminal violation, he was not entitled to relief under the statute, holding that a person charged with a first violation of driving with a suspended license is entitled to have his records sealed under the provisions of section 12-1-12. In denying Defendant's motion to seal his records, the trial judge looked to the language of the statute, noting that it speaks only to criminal cases and is silent with respect to civil violations, and concluded that the Legislature had provided no mechanism to seal or expunge civil violations. The Supreme Court disagreed, holding that where Defendant was detained by police but not arrested or charged with an offense, he was entitled to the benefits of section 12-1-12(a) with respect to the destruction and sealing of his records. View "State ex rel. Coventry Police Department v. Charlwood" on Justia Law

by
The Supreme Court affirmed the orders of the superior court dismissing Plaintiff's claims against Defendants, USAA Federal Savings Bank and Charles Baird, for lack of personal jurisdiction, holding that the trial justice was correct in finding that the superior court did not have personal jurisdiction over Defendants. This case stemmed from an alleged oral agreement between Plaintiff and Baird. Plaintiff was a resident of Rhode Island, and Baird was a resident of Florida. Plaintiff filed a complaint against both Baird and USAA, a bank incorporated and based in Texas with whom Baird maintained a personal checking account, seeking to recover certain funds plus consequential damages.The superior court dismissed the case against both defendants for lack of personal jurisdiction. The Supreme Court affirmed, holding (1) the superior court was correct in finding that it did not have either general personal jurisdiction or specific jurisdiction over USAA; and (2) the trial justice was correct in finding that the superior court did not have specific personal jurisdiction over Baird. View "Edward F. St. Onge v. USAA Federal Savings Bank" on Justia Law

by
The Supreme Court affirmed the judgment of the superior court affirming a decision of the Rhode Island Department of Labor and Training (DLT) that denied Petitioners' wage and hour claims against Delta Airline, Inc., holding that the superior court did not err in affirming the DLT's finding that R.I. Gen. Laws 25-3-3 was preempted by federal law. Petitioners were customer service agents for Delta at its facility at the T.F. Green Airport in Warwick, Rhode Island. Petitioners filed separate individual "nonpayment of wages" complaints with DLT, alleging that Delta violated the provisions of section 25-3-3 by failing to pay Petitioners time-and-a-half for hours worked on Sundays and holidays. The hearing officer determined that section 25-3-3 was preempted by section 49 U.S.C. 41713(b)(1) of the Airline Deregulation Act (ADA). The superior court affirmed. The Supreme Court affirmed, holding that Petitioners' claims were preempted by the ADA. View "Brindle v. Rhode Island Department of Labor & Training" on Justia Law

by
The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendants on the grounds that the case was moot, holding that there was no justiciable controversy before the Court and that Plaintiffs failed to meet the burden of demonstrating that the issues raised in their complaint were of extreme public importance and were capable of repetition yet will evade review. After the National Education Association Rhode Island and the Middletown Teachers' Association/NEA (collectively, the Union) and the Middletown School Committee (school committee) reached a tentative successor agreement to a collective bargaining agreement (CBA) that was due to expire the Town of Middletown refused to ratify the agreement. The Union filed suit challenging the denial. Thereafter, the parties agreed to a new three-year CBA, and the Town voted to ratify the agreement. The trial justice granted summary judgment for Defendants, the Town, the school committee, and the Middletown School Department. The Supreme Court affirmed, holding that the trial justice did not err in granting summary judgment on the basis of mootness and that no exceptions to the mootness doctrine existed. View "National Education Ass'n Rhode Island v. Town of Middletown" on Justia Law

by
The Supreme Court vacated the judgments of the superior court granting summary judgment in favor of the defendant and the third-party defendant (collectively, Defendants) on Plaintiff's complaint alleging negligence for her injuries and the third-party complaint seeking to defend, indemnify, and hold the third-party defendant harmless for claims arising out of the third-party defendant's duty under Defendants' snow services agreement, holding that genuine issues of material fact existed precluding summary judgment. Specifically at issue before the trial justice was whether there were genuine issues of material fact as to the dangerous condition that caused Plaintiff's fall that would preclude summary judgment. The trial justice weighed the evidence before her at least twice during the summary judgment hearing. The Supreme Court vacated the superior court's judgments, holding that the trial justice improperly weighed the evidence before her at the summary judgment hearing. View "Voccola v. Stop & Shop Supermarket Co." on Justia Law

by
In these actions challenging the assessment of alleged illegal real estate taxes on several properties and property owners, the Supreme Court affirmed the judgment of the superior court in favor of Defendants in the declaratory judgment action and denied and dismissed the appeal in the tax appeal action, holding that the Plaintiff did not have standing in either action. Defendants were various officials of the Town of Barrington, Rhode Island; Sweetbriar, LP; and East Bay Community Development Corporation. Plaintiff was the owner of property located in Barrington. Plaintiff filed a complaint appealing the assessment of his property (tax appeal action) and filed a separate declaratory judgment action. In essence, Plaintiff argued that he was forced to pay a higher amount on his taxes because of Sweetbriar's favorable tax treatment under R.I. Gen. Laws 44-5-12 and 44-5-13.11. The hearing justice ruled that Plaintiff lacked standing to bring either action. The Supreme Court affirmed, holding (1) Plaintiff lacked standing to bring the declaratory judgment action; and (2) the hearing justice did not err in determining that Plaintiff lacked standing to challenge Barrington's application of section 44-5-12 and 44-5-13.11 to the Sweetbriar development, along with another project. View "Morse v. Minardi" on Justia Law

by
The Supreme Court quashed the order of the superior court denying Plaintiff’s motion for a protective order concerning the deposition of Lawrence Rainey, holding that, pursuant to rule 26(b)(4)(B) of the Superior Court Rules of Civil Procedure, Defendants failed to demonstrate “exceptional circumstances” to depose Rainey, a nontestifying expert. On appeal, Plaintiff argued that Rainey was a nontestifying expert and therefore may not be deposed absent a showing of exceptional circumstances in accordance with Rule 26(b)(4)(B). The Supreme Court agreed, holding (1) Rule 26(b)(4)(B) is applicable to the discovery issue here; (2) the hearing justice erred in failing properly to apply the Rule 26(b)(4)(B) standard in this case; and (3) Defendants failed to demonstrate “exceptional circumstances” as to why they wished to depose Rainey. View "Sandy Point Farms, Inc. v. Sandy Point Village, LLC" on Justia Law