Justia Rhode Island Supreme Court Opinion Summaries

Articles Posted in Civil Procedure
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The Supreme Court of Rhode Island heard an appeal by Kelly Maltais contesting the dismissal of her probate appeal by the Superior Court. Kelly challenged the last will and testament of her father, Laurent E. Maltais, alleging fraud, duress, and undue influence, and asserting that her father lacked testamentary capacity. Kelly's probate appeal was dismissed by the Superior Court on the grounds that it was filed 32 days after the probate court order, two days beyond the statutory 30-day limit for appeal. Kelly argued that the 30th day fell on a Saturday, and under Rule 6 of the Superior Court Rules of Civil Procedure, she had until the following Monday to file her appeal.The Supreme Court of Rhode Island vacated the order of the Superior Court, ruling that the computation of time for the 30-day deadline is tolled when the last day for filing falls on a Saturday, Sunday, or a legal holiday, in order to give appellants the full benefit of all the time allowed, even if it necessitates giving an additional day. The case was remanded to the Superior Court for further proceedings consistent with this opinion. View "Maltais v. Maltais" on Justia Law

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The case involves an appeal by a landlord, Carline Vilbon, against her tenant, Judy Vargas, in an eviction action. The landlord had sought possession of the rental property and reasonable use and occupancy damages from the termination date through the date Vargas vacated the property. The Superior Court granted Vilbon possession but dismissed her claim for use and occupancy as well as for money damages. Vilbon appealed the Superior Court's decision to the Supreme Court of Rhode Island.The Supreme Court of Rhode Island affirmed the order of the Superior Court. The court found that without a transcript of the proceedings, it could not determine whether the trial justice had abused his discretion in either dismissing Vilbon’s claims or denying her motion to vacate the consent order. The court held that the burden of furnishing the court with the necessary records to enable it to pass on the alleged error lay with the party alleging the error. As such, the court concluded that Vilbon's failure to provide an adequate transcript was fatal to her claims. View "Vilbon v. Vargas" on Justia Law

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The Supreme Court quashed the decision of the superior court granting Defendant's motion to compel production of a complete, unreacted copy of a settlement agreement between Plaintiffs and the former codefendants who settled Plaintiffs' claims, holding that the trial justice abused her discretion in granting Defendant's motion.In granting Defendant's motion to compel production, the trial justice concluded that the amount paid in accordance with the settlement agreement was not discoverable "pursuant to Rhode Island and federal law." When Plaintiffs failed to comply with the order the superior court granted Defendant's motion to dismiss. The Supreme Court quashed the decision below and remanded the case, holding that the trial justice abused her discretion in granting Defendant's motion to compel production of a complete, unreacted copy of the settlement agreement. View "Noonan v. Sambandam" on Justia Law

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The Supreme Court affirmed the orders of the superior court in these three related by unconsolidated appeals, holding that Appellants were not entitled to relief on their arguments on appeal.In No. 2021-303-A and No. 2021-331-A, defendants Thomas and John Mercurio appealed pro se from a superior court granting the motion to adjudge the Mercurios in contempt filed by plaintiffs Dean and Melissa Pinelli. In No. 2021-331-A, plaintiff Elena Massarone appealed pro se from a superior court order granting the Pinellis' motion to adjudge Elena in civil contempt. On appeal, Elena and the Mercurios both asserted largely identical claims of error. The Supreme Court affirmed in all cases, holding that because none of the appellants provided transcripts to the Court from any of the hearings held throughout the proceedings and because their statements failed to provide any cogent legal analysis or substantive discussion of their claims, the appellants waived their arguments on appeal. View "Pinelli v. Mercurio" on Justia Law

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The Supreme Court affirmed the judgment of the superior court dismissing Plaintiffs' claims based on lack of standing, holding that there was no error.In 2019, the General Assembly enacted the Reproductive Privacy Act, R.I. Gen. Laws chapter 4.13 of title 23 (RPA), effectively granting a right to abortion in line with Roe v. Wade. 410 U.S. 113 (1973). Plaintiffs initiated this action seeking to halt the passage of House Bill 5125, Substitute B, which later became the RPA. The trial justice denied relief. Plaintiffs then filed a complaint challenging the General Assembly's authority to enact the RPA. The trial court granted Defendants' motion to dismiss for failure to state a claim. The Supreme Court affirmed, holding that Plaintiffs lacked standing to bring their claims. View "Benson v. McKee" on Justia Law

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The Supreme Court affirmed the superior court's entry of partial final judgment in accordance with Sup. Ct. R. Civ. P. 54(b) and the dismissal for lack of personal jurisdiction of Plaintiff's action under Sup. Ct. R. Civ. P. 12(b)(2) as to certain defendants, holding that the hearing justice did not err.At issue was the superior court's authority to exercise jurisdiction over claims brought against foreign corporate defendants based on a fatal injury to a Rhode Island resident following an accident that occurred outside of Rhode Island. The corporate defendants filed a motion to dismiss for lack of jurisdiction, which the hearing justice granted. Partial final judgment pursuant to Rule 54(b) was entered in favor of the corporate defendants. The Supreme Judicial Court affirmed, holding that the hearing justice (1) did not err in dismissing the claims against the corporate defendants based on a lack of personal jurisdiction; and (2) did not err in denying Plaintiff's request to conduct jurisdictional discovery. View "Martins v. Bridgestone Americas Tire Operations, LLC" on Justia Law

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The Supreme Court affirmed the order of the superior court denying Defendants' appeal of a superior court order denying their "motion to vacate" a foreign judgment rendered in New York, which was brought in accordance with the Uniform Enforcement of Foreign Judgments Act, chapter 32 of title 9 of the Rhode Island General Laws, holding that the superior court did not err.In denying Defendants' motion to vacate, the hearing justice concluded that Defendants did not meet their "heavy burden" to overturn the New York default judgment. The Supreme Court affirmed, holding (1) New York law must be applied in addressing the forgery argument presented by Defendants; (2) applying New York law, Defendants failed to meet their burden of rebutting the presumption of due execution accompanying acknowledgements and notarial signatures, and therefore, the subject forum selection clause was valid; and (3) the New York court had personal jurisdiction over Defendants. View "Aspen American Insurance Co. v. East Coast Precast & Rigging LLC" on Justia Law

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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

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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
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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