Justia Rhode Island Supreme Court Opinion Summaries

The Department of Children, Youth, and Families (DCYF) filed petitions to terminate the parental rights of a father to his three sons, B.M., A.M., and N.M., based on allegations of unfitness. The petitions cited that the children had been in DCYF care for over twelve months without a substantial probability of returning to the father within a reasonable period. The father had moved out of state, inconsistently engaged in required services, and failed to maintain regular visitation with his children. The children were placed in a foster home where they thrived and expressed a desire not to return to their father.The Family Court held a bench trial over several days, admitting various exhibits and hearing testimonies from DCYF caseworkers, therapists, and the father. The court found by clear and convincing evidence that the father was unfit due to his failure to complete required services, inconsistent visitation, and inability to provide a stable environment. The court also found that the children were well-adjusted and bonded with their foster mother, and it was in their best interests to terminate the father's parental rights.The Rhode Island Supreme Court reviewed the case and affirmed the Family Court's decree. The Supreme Court found that there was competent evidence supporting the Family Court's findings of unfitness, DCYF's reasonable efforts to reunify the family, and that termination of parental rights was in the best interests of the children. The Supreme Court noted that the father’s inconsistent engagement with services and visitation, along with the children’s expressed wishes and well-being in their foster home, justified the termination of his parental rights. View "In re B.M." on Justia Law

The case involves the divorce of Jose A. Saldana and Daisy M. DeJesus, who married in 2004 and separated in 2009. During their marriage, Saldana purchased a home on Whitmarsh Street, which was later transferred to include DeJesus on the title. After their separation, DeJesus moved to Pennsylvania and later returned to Rhode Island, purchasing another property on Atwells Avenue with her mother. DeJesus filed for divorce in 2018, and the Family Court awarded her the Whitmarsh property, while Saldana retained his pension.The Family Court granted the divorce on grounds of irreconcilable differences and divided the couple's assets accordingly. Saldana did not appeal the final judgment. Later, DeJesus filed a motion to hold Saldana in contempt for not cooperating with refinancing the Whitmarsh property. Saldana filed a motion to vacate the final judgment, arguing that it did not reflect their agreement and that DeJesus had not disclosed all her assets. The Family Court magistrate denied this motion, and Saldana did not appeal.Saldana then filed a second motion to vacate, which was partially granted regarding the Atwells property but denied concerning the Whitmarsh property. The Family Court justice upheld the magistrate's decision, and Saldana appealed to the Rhode Island Supreme Court. The Supreme Court affirmed the Family Court's order, noting that Saldana's second motion to vacate was untimely and should have been dismissed. The issue of the Atwells property remains pending for further proceedings. View "DeJesus v. Saldana" on Justia Law

The case involves a petitioner who filed a miscellaneous petition in Family Court concerning a child whose parents are the respondent and the late Christine Hasselbrock. The petitioner, who had a long-standing platonic relationship with Ms. Hasselbrock, provided financial and emotional support to her and her child. After Ms. Hasselbrock's death, the petitioner sought to be declared a de facto parent or to have other parental rights recognized, but the respondent denied him access to the child.Initially, the petitioner filed an amended verified petition in Family Court, asserting both statutory and common law claims for de facto parentage. The first hearing justice dismissed the statutory claim due to lack of standing, as the petitioner had never resided with the child. The justice indicated that the petitioner could pursue his common law claims on the miscellaneous calendar. Consequently, the petitioner filed a new miscellaneous petition asserting various common law claims, including de facto parentage, in loco parentis, and visitation rights.The Rhode Island Supreme Court reviewed the case and affirmed the Family Court's orders. The Court held that the Rhode Island Uniform Parentage Act (UPA) supersedes common law de facto parentage claims, as the statute explicitly outlines the criteria for establishing de facto parentage. The Court also found that the petitioner lacked standing to pursue claims for visitation based on being an "unrelated caregiver" or "de facto relative," as there is no statutory authority granting such rights. Additionally, the Court affirmed the denial of the respondent's motion for attorneys' fees, finding no basis for such an award. View "De Vries v. Gaudiana" on Justia Law

The Department of Children, Youth, and Families (DCYF) became involved with A.N.'s family after the Rhode Island State Police informed them that A.N.'s father, Francis N., had been arrested on felony charges, including indecent solicitation of a child and electronically disseminating indecent material to a minor. Following his arrest, DCYF initiated an investigation and found that Francis had admitted to soliciting sex from a fictitious 13-year-old girl online. Consequently, DCYF filed a neglect petition against Francis, alleging that he failed to provide A.N. with proper care and supervision.The Family Court granted DCYF temporary custody of A.N. and later held a permanency hearing, ordering that A.N. remain in DCYF's care. Despite DCYF's efforts to engage Francis in services and case planning, he refused to comply, including declining to submit to a sex offender evaluation. During the neglect petition hearing, Francis invoked his Fifth Amendment right against self-incrimination multiple times when questioned about his criminal charges and his involvement with A.N. The Family Court found by clear and convincing evidence that Francis neglected A.N., citing his failure to provide care, supervision, or guardianship, and his lack of engagement with DCYF.The Rhode Island Supreme Court reviewed the case and affirmed the Family Court's decree. The Supreme Court held that it was proper for the Family Court to draw adverse inferences from Francis's invocation of his Fifth Amendment right in a civil proceeding. The Court found clear and convincing evidence supporting the Family Court's finding of neglect, noting Francis's refusal to engage in necessary services, his lack of financial support for A.N., and his displacement of A.N. from the family home. The Supreme Court concluded that Francis's actions demonstrated a disregard for A.N.'s safety and needs. View "In re A.N." on Justia Law

The plaintiff and defendant were married in 1976 and divorced in 1999. Their marital settlement agreement (MSA) stipulated that their marital home would be sold, and the proceeds divided equally. The plaintiff was responsible for household expenses until the sale. The home was not sold until 2019, after the defendant filed a partition action. The defendant then sought specific performance, alleging the plaintiff breached the MSA by preventing repairs and refusing to divide property. The plaintiff counterclaimed, seeking reimbursement for expenses incurred due to the delayed sale and other breaches by the defendant.The Family Court granted in part and denied in part the defendant's motion for summary judgment. It found the MSA clear and unambiguous, except for the clause about splitting the pool bill. The court ruled that the plaintiff was not entitled to reimbursement for expenses related to the marital home, as the MSA did not specify such obligations. The court awarded the defendant the 1982 Mercedes Benz and ordered the division of remaining funds and personal property. The plaintiff was awarded additional amounts for storage costs and attorney fees.The Rhode Island Supreme Court reviewed the case. It affirmed the Family Court's orders, agreeing that the MSA was clear and unambiguous regarding household expenses and that the plaintiff failed to pursue the proper remedy of specific performance for the defendant's alleged breaches. The court also upheld the award of the Mercedes Benz to the defendant and the distribution of funds and personal property. The plaintiff's additional claims for storage costs and contempt were not addressed due to procedural issues and lack of adequate argumentation. View "Jeremiah v. Estate of Jeremiah" on Justia Law

This case involves a dispute over the Estate of Donelson C. Glassie. The plaintiff, Marcia Sallum Glassie, was married to Donelson C. Glassie, and they divorced in 1993. According to their property-settlement agreement, the testator was to execute a will that would treat his obligations under the agreement as a claim against his estate and bequest to the plaintiff an amount equal to said obligations. A dispute arose over what the agreement required of the testator’s will. In 1997, a Family Court justice determined that the plaintiff was entitled to a bequest of a sum equal to the testator’s obligations. The testator died in 2011, and the plaintiff filed a claim for $2,000,000 against the testator’s estate a year later, which the defendant disallowed.The case was previously reviewed by the Superior Court, which awarded the plaintiff $2,000,000, less the proceeds of a life insurance policy that she received upon the testator’s death and attorneys’ fees. However, this judgment was vacated by the Supreme Court on multiple grounds, including that the disputed provision in the will was ambiguous and required factfinding and conclusions of law with respect to the testator’s intent.In the current review by the Supreme Court of Rhode Island, the plaintiff argued that the trial justice made numerous prejudicial evidentiary rulings that prevented her from presenting her case. After reviewing the record and considering the parties’ arguments, the Supreme Court affirmed the judgment of the Superior Court. The court found no error in the trial justice’s decisions to prevent the plaintiff from presenting evidence regarding a trust, to allow the defendant to withdraw certain admissions, to admit evidence of a life insurance policy, and to allow evidence of the defendant’s post-death conduct. The court also found that the plaintiff had not preserved her argument regarding the trial justice’s decision to prevent her from examining the defendant about his counterclaim. View "Glassie v. Doucette" on Justia Law

Danielle LeFebvre was convicted of first-degree child abuse after her seven-week-old son suffered life-threatening injuries. LeFebvre claimed that her son's injuries were accidental, resulting from a fall from her bed. However, medical examinations revealed complex skull fractures, brain contusions, and rib fractures consistent with abuse. LeFebvre was sentenced to twenty years in prison, with eighteen years to serve and the balance suspended, with probation. She appealed her conviction, but it was affirmed.LeFebvre then filed an application for postconviction relief, arguing that she was deprived of effective assistance of counsel. She claimed her trial counsel failed to consult and present a medical expert at trial and disclosed harmful information to the prosecution. The Superior Court denied her application, finding that her counsel's decision to disclose her medical records was a tactical one and that the absence of expert testimony did not deprive LeFebvre of effective assistance of counsel.LeFebvre appealed to the Supreme Court of Rhode Island, which affirmed the judgment of the Superior Court. The court found that while the disclosure of LeFebvre's medical records was objectively unreasonable, it did not deprive her of a fair trial given the overwhelming evidence of her guilt. The court also found that the failure to consult and present an expert at trial did not satisfy the criteria for ineffective assistance of counsel. View "LeFebvre v. State" on Justia Law

A fatal motor vehicle accident involving a juvenile driver led to a delinquency petition filed against the driver, who later pleaded nolo contendere to two charges of driving so as to endanger, resulting in death. The parents of the deceased, who were present for the plea, subsequently filed a motion in the Family Court seeking access to the transcript of the proceeding where the juvenile driver was certified and sentenced. The Family Court denied the motion, leading to an appeal by the deceased's parents, who were not parties to the case.The Family Court's denial of the motion was based on the consideration of the "good cause" standard, as stipulated by the statute and precedent. The court found that the parents failed to show how they would not be able to seek restitution for their damages without the transcript. The court also noted that the parents and their attorneys were present during the proceedings for which they requested a transcript. Balancing the interests of the state in protecting the confidentiality of juvenile justice proceedings against the interests of the parents, the court concluded that the state's interests outweighed the parents' interests.The Supreme Court of Rhode Island affirmed the Family Court's order. The Supreme Court noted that the parents failed to meet the standard for production of confidential juvenile records of Family Court proceedings. The court also disagreed with the parents' argument that the transcript might prove helpful in the event of inconsistencies in the juvenile's testimony, describing this argument as speculative. The court concluded that the Family Court did not abuse its discretion in denying the motion. View "In re C.R." on Justia Law

The case involves the Department of Children, Youth, and Families (DCYF) in Rhode Island, which was held in contempt by the Family Court for failing to place a minor, N.B., in a specific facility, St. Mary’s Home for Children, as ordered by the court. N.B., who has behavioral issues and Type I juvenile diabetes, was initially placed in Hasbro Children’s Hospital after her mother refused to take her home due to safety concerns. The Family Court ordered DCYF to place N.B. at St. Mary’s, but the facility refused to admit her due to her medical needs and behavioral issues. Despite DCYF's efforts to secure a placement for N.B., including contacting multiple potential placements and attempting to hire nurses to monitor N.B.'s diabetic care needs, no suitable placement was available.The Family Court found DCYF in contempt for failing to place N.B. at St. Mary’s, rejecting DCYF's argument that it was impossible to comply with the placement order. The court ordered DCYF to pay a daily sanction until it complied with the order. DCYF appealed the contempt order, arguing that the Family Court abused its discretion by finding that DCYF had not exercised reasonable efforts to place N.B. and that it was impossible to comply with the placement order.The Supreme Court of Rhode Island vacated the Family Court’s contempt order. The Supreme Court found that DCYF had made substantial efforts to place N.B. at St. Mary’s and other appropriate facilities, but compliance with the placement order was outside the department’s control due to circumstances such as the refusal of facilities to accept N.B. and ongoing nursing shortages related to the COVID-19 pandemic. The Supreme Court concluded that the Family Court had abused its discretion in finding that DCYF had not used reasonable efforts to place N.B. and in holding DCYF in contempt. View "In re N.B." on Justia Law

The case involves the Department of Children, Youth, and Families (DCYF) in Rhode Island, which was held in contempt by the Family Court for failing to place a minor, N.D., in a residential facility appropriate for her level of need. N.D., a teenager with severe mental health issues, was under the temporary custody of DCYF. Despite the court's order, DCYF was unable to find an appropriate in-state or out-of-state placement for N.D. due to her high level of need and the lack of available facilities. The Court Appointed Special Advocate (CASA) filed a motion to adjudge DCYF in contempt for this failure.The Family Court found DCYF in contempt, rejecting DCYF's defense that it was unable to comply with the court's order. The court imposed a contempt sanction of $1,000 per day until N.D. was placed in an appropriate facility, with the sanction to be placed in a trust for N.D.'s benefit. DCYF appealed this decision.The Supreme Court of Rhode Island vacated the order of the Family Court. The Supreme Court found that while DCYF was in technical violation of the Family Court's order, it had demonstrated that it was literally unable to comply because an appropriate placement for N.D. was not presently within its power. The court noted the lack of appropriate facilities for girls with N.D.'s level of need in Rhode Island, staffing issues, and an increase in mental health problems among adolescents. The case was remanded to the Family Court for further proceedings. View "In re N.D." on Justia Law