Justia Rhode Island Supreme Court Opinion Summaries

In 2011, the Town of Middletown issued an invitation for bids on a drainage improvement project. Two contractors submitted bids, including HK&S Construction Holding Corp., which provided the lowest bid. Woodard & Curran, Inc. recommended against awarding HK&S the project and in favor of negotiating a contract with the second bidder. The town counsel concluded that HK&S’s bid was non-responsive and awarded the contract to the second bidder. Plaintiff filed a complaint against the Town and Woodard & Curran alleging, among other claims, that the Town violated state and local law when it denied the contract award for the project. The superior court granted summary judgment for Defendants. The Supreme Court affirmed, holding (1) there was no error in disposing of HK&S’s claims against the Town in summary judgment where HK&S failed to submit a responsive bid; and (2) HK&S’s claim of negligence against Woodard & Curran also failed. View "HK&S Constr. Holding Corp. v. Dible" on Justia Law

After a jury trial, Defendant was found guilty of disorderly conduct and sentenced to six months’ incarceration. The Supreme Court affirmed the judgment of conviction and the denial of Defendant’s motion for a new trial and motion for a judgment of acquittal, holding (1) the trial justice did not err in denying Defendant’s motion for a new trial, as his speech rose to the level of the criminal offense with which he was charged; (2) there was sufficient evidence to convict Defendant; and (3) Defendant’s argument that the criminal complaint lodged against him was insufficient as a matter of law to place him on notice of the charge against him was not properly preserved for appellate review. View "State v. Matthews" on Justia Law

After a jury trial, Defendant was convicted of resisting arrest and disorderly conduct. Defendant appealed, asserting that her right to counsel guaranteed by both the federal and state Constitutions was violated when the trial justice allowed her to represent herself at trial without first determining whether she had made a knowing and intelligent waiver of her right to counsel. The Supreme Court affirmed, holding that, upon consideration of the totality of the circumstances at the time of Defendant’s waiver, the record established Defendant’s voluntary, knowing, and intelligent waiver of her right to counsel. View "State v. Cruz" on Justia Law

In 2000, Plaintiff filed a suit against Defendant in her capacity as Treasurer and Finance Director of the Town of Cumberland, alleging age discrimination in hiring and retaliation. After a trial, a verdict was returned for Plaintiff on both counts. Upon motion by Defendant, however, the verdicts were vacated and a judgment as a matter of law was entered for Defendant on both counts. Alternatively, the trial justice granted Defendant’s motions for a new trial on both claims. The Supreme Court vacated the trial justice’s finding on the discrimination claim. On remand, the case was retried before a second jury. The jury returned a verdict for Defendant. Plaintiff filed a motion for a new trial, which the trial justice denied. The Supreme Court affirmed, holding (1) the trial justice did not abuse her discretion in disallowing questioning on portions of a 1999 letter from Defendant’s counsel to the Commission of Human Rights; (2) the trial justice’s refusal to impart a jury instruction on a federal regulation and a state statute did not misconstrue the law; and (3) the judge did not err in now allowing Plaintiff to present evidence of his retaliation claim. View "McGarry v. Pielech" on Justia Law

Respondents, two firefighters, objected to orders from their superiors that they serve as part of the crew of a fire engine in the 2001 Pride Parade. Notwithstanding their objections, Respondents were ordered to cary out the task assigned, and they reluctantly took part in the parade. Thereafter, Respondents sued Petitioners, the former Providence Mayor and former Chief of the Providence Fire Department, as well as the City of Providence, on a variety of state and federal claims. Petitioners moved for summary judgment on two of those claims, invoking the doctrine of qualified immunity from suit. The superior court denied the motion for summary judgment. The Supreme Court quashed the judgment of the superior court, holding that, in view of the facts of this case, it was not necessary to invoke the doctrine of qualified immunity because no constitutional violation occurred. Remanded with instructions that Petitioners’ motion for summary judgment be granted. View "Fabrizio v. City of Providence" on Justia Law

Plaintiff allegedly suffered from chronic headaches, which she treated with the medication Percocet, while enrolled in the nursing program at the Community College of Rhode Island (CCRI). Plaintiff filed a disability discrimination action against CCRI, the Board of Governors for Higher Education, and two individuals (collectively, Defendants), alleging that she had been dropped from the nursing program at CCRI because of her disability. The jury reached a verdict for Defendants. The Supreme Court affirmed, holding that the trial justice did not err by (1) admitting into evidence a medical report prepared by a neurologist who treated Plaintiff after she left the college; and (2) excusing a juror on the fourth day of trial due to concerns about his objectivity. View "Thornley v. Cmty. College of R.I." on Justia Law

After a second jury trial, Defendant was convicted of one count of felony assault, one count of simple assault, and one count of first-degree child abuse. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice (1) did not abuse his discretion by denying Defendant’s motion for a continuance in order for the defense to investigate genetic-testing results that were provided to the defense during jury selection in the second trial; and (2) did not err or violate Defendant’s right to present a defense by prohibiting Defendant’s father from testifying in Defendant’s case-in-chief. View "State v. Verry" on Justia Law

Defendant pled guilty to second-degree murder and was sentenced to life imprisonment. This appeal concerned Defendant’s third attempt to challenge his plea and sentence with a motion to reduce or correct sentence pursuant to Rule 35 of the Superior Court Rules of Criminal Procedure. The trial justice denied the motion. Defendant appealed, arguing that his life sentence was illegal because he should have been convicted of manslaughter, which carries a maximum sentence of thirty years, and that the continued imposition of his purportedly illegal sentence constituted a violation of the Eighth Amendment to both the federal and the state Constitutions. The Supreme Court affirmed, holding that there was no error in the hearing justice’s decision to deny the Rule 35 motion and that Defendant’s constitutional arguments had no merit. View "State v. Miguel" on Justia Law

In the town of Tiverton, two police officers from the Little Compton police department had a discussion with Defendant about a motor-vehicle accident that occurred in Little Compton. The officers then transported Defendant in a police cruiser back to the scene of the accident, where they administered field-sobriety tests, which Defendant failed. Defendant was subsequently charged with driving under the influence of liquor or drugs, among other offenses. Defendant filed a motion to dismiss due to an unlawful arrest, arguing that the officers lacked the authority to arrest him in Tiverton. The trial judge concluded that the arrest was unlawful and dismissed the case. The Supreme Court quashed the judgment of the district court, holding that Defendant was not arrested by the Little Compton police while they were in Tiverton, and therefore, the trial judge erred when she granted Defendant’s motion to dismiss. Remanded.View "State ex rel. Town of Little Compton v. Simmons" on Justia Law

Defendant hired Plaintiff twice when Plaintiff was sixty-seven years old for brief periods of employment. When Plaintiff was sixty-eight, Defendant rehired her as a titles and registrations clerk. When Plaintiff was seventy-two years old, Defendant terminated her employment. Plaintiff filed an action against Defendant for unlawful age and disability discrimination in violation of the Fair Employment Practices Act. The superior court granted summary judgment for Defendant on both employment discrimination claims. The Supreme Court affirmed, holding that the trial justice did not err (1) in finding that Defendant met its burden of producing a legitimate nondiscriminatory reason for Plaintiff’s dismissal, and (2) in holding that Plaintiff failed to demonstrate that those reasons were merely pretextual.View "Bucci v. Hurd Buick Pontiac GMC Truck, LLC " on Justia Law