Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the family court trial justice affirming the decision and order entered by the General Magistrate of the family court granting Plaintiff's motion to relocate permanently to the Commonwealth of Massachusetts with the parties' minor child, holding that there was no error.Plaintiff filed this action and an ex parte motion seeking temporary custody and physical possession of the parties' child. The court granted the motion, after which Plaintiff filed a verified emergency motion to relocate to Massachusetts. The family court granted the emergency motion to relocate. The general magistrate granted the motion to relocate, and the family court affirmed. The Supreme Court affirmed, holding that the family court did not erroneously affirm the general magistrate's decision and order concluding that allowing Plaintiff to relocate permanently to Massachusetts was in the child's best interests. View "Dawson v. Ojeda" on Justia Law

The Supreme Court affirmed the decree of the family court terminating Mother's parental rights with respect to her daughter (Child), holding that the trial justice did not err in finding by clear and convincing evidence that the Department of Children, Youth, and Families (DCYF) made reasonable efforts to achieve reunification between Mother and Child.DCYF filed a petition to terminate Mother's parental rights on the grounds that she and Father were unfit to parent Child under R.I. Gen. Laws 15-7-7(a)(2)(i) and (a)(3). After a trial, the trial justice granted DCYF petition to terminate Mother's parental rights, determining that DCYF met its burden of proving by clear and convincing evidence that it employed reasonable efforts to achieve reunification. The Supreme Court affirmed, holding that the trial justice did not clearly error or overlook or misconceive material evidence in determining that DCYF made reasonable efforts to achieve reunification. View "In re R.M." on Justia Law

The Supreme Court vacated the orders of the family court reopening a divorce case finalized by the family court more than two decades ago and awarding Steven Capaldi a portion of his pension to Anne Farrer, holding that the trial justice's decision granting Anne's motion for relief was incorrect as a matter of law.In 1993, the family court entered final judgment in the underlying divorce case. In 2017, Anne filed a motion for post-judgment relief seeking an award of one-half interest in the marital portion of Steven's pension on the ground that Steven "concealed" the pension at the time of the divorce. The trial justice granted relief. The Supreme Court vacated the decision below, holding that the statute of limitations in R.I. Gen. Laws 9-1-17 barred Anne's belated request to reopen the final judgment. View "Capaldi v. Capaldi" on Justia Law

The Supreme Court affirmed the decision of the family court determining and assigning marital property, sanctioning Defendant $50,000, and ordering a $16,000 credit to Plaintiff, holding that Defendant was not entitled to relief on his allegations of error.In 2000, the parties in this case married, and in 2017, the parties initiated divorce proceedings based on irreconcilable difference. At issue before the Supreme Court was the trial court's determination and equitable distribution of marital assets. After an eight-day trial, the trial justice issued a bench decision. Defendant appealed. The Supreme Court affirmed, holding that the trial justice (1) did not err in the determination and assignment of marital assets; (2) did not err in the imposition of sanctions; and (3) did not abuse her discretion in ordering a $16,000 credit to Plaintiff. View "DiDonato v. DiDonato" on Justia Law

The Supreme Court affirmed the decree of the family court terminating Father's parental rights to his daughter, R.M., holding that Father was not entitled to relief as to his arguments on appeal.The Department of Children, Youth, and Families (DCYF) filed a petition to terminate the parental rights of Father based on his incarceration and the child's placement the care of DCYF for more than twelve months. The trial justice ultimately determined that DCYF had met its burden of proof for the termination of parental rights petition by clear and convincing evidence and that termination of Father's parental rights was in the best interests of the child. The Supreme Court affirmed, holding that the trial justice did not err in (1) its finding as to parental unfitness; (2) finding that DCYF made reasonable efforts to "encourage and strengthen the parental relationship"; and (3) determining that it was in R.M.'s best interests for Father's parental rights to be terminated. View "In re R.M." on Justia Law

The Supreme Court affirmed the decree of the family court in favor of Mother and permitting Mother to vaccinate the parties' two minor children for COVID-19 consistent with the recommendation of the children's pediatrician, holding that there was no error.In 2020, the family court entered a final judgment of divorce between the parties setting forth provisions governing the children's custody and visitation, including the provision that "[n]either party shall unreasonably withhold his or her consent to medical treatment for the children or the administration of medication recommendation by the pediatrician of the children." In 2022, Plaintiff filed a motion for relief after final judgment seeking the court's permission to vaccinate the children for COVID-19, consistent with the pediatrician's recommendation. The trial justice allowed the motion. The Supreme Court affirmed, holding that the trial justice's factual findings did not overlook or misconceive any aspect of the matter, nor were they otherwise clearly wrong. View "Nagel v. Nagel" on Justia Law

The Supreme Court affirmed the decree of the family court issued pursuant to R.I. Gen. Laws 15-7-7(a)(3) terminating Father's parental rights to his son, J.B. holding that there was no error in the proceedings below.The Department of Children, Youth, and Families filed a petition in the family court to terminate the parental rights of Father based on two grounds of unfitness. After a trial, the trial justice found clear and convincing evidence that Father was not a fit parent who could care for J.B. immediately and that it was in J.B.'s best interests to terminate Father's parental rights. The Supreme Court affirmed, holding that competent evidence supported the findings of the trial justice that Father was an unfit parent pursuant to section 15-7-7(a)(3) and that termination of Father's parental rights was in J.B.'s best interests. View "In re J.B." on Justia Law

The Supreme Court affirmed the decision of the trial justice awarding attorneys' fees to Plaintiff in this divorce action, holding that there was no error.Plaintiff filed a complaint for divorce, and Defendant filed a counterclaim for divorce. As to attorneys' fees, the trial justice found that Plaintiff was entitled to reasonable attorneys' fees pursuant to the parties' postnuptial agreement's fee-shifting provision, as well as R.I. Gen. Laws 15-5-16. Defendant appealed, challenging the award of attorneys' fees. The Supreme Court affirmed, holding that the trial justice had both a statutory and contractual basis to award Plaintiff attorneys' fees and costs and did not abuse his discretion in making the award. View "McCollum v. McCollum" on Justia Law

The Supreme Court affirmed the decree of the family court terminating Father's parental rights to his two children pursuant to R.I. Gen. Laws 15-7-7(a)(3), holding that there was no error or abuse of discretion.On appeal, Father argued that a finding of unfitness was at odds with the evidence presented and that the Department of Children, Youth and Families did not make reasonable efforts toward reunification. The Supreme Court affirmed, holding (1) legally competent evidence existed to support the trial justice's findings as to parental unfitness; (2) the trial justice's conclusion on the issue of reasonable efforts to reunify was not clearly erroneous; and (3) there was no error either in the permanency hearing, as conducted by the trial justice, or in the subsequent decision. View "In re Jae'La G." on Justia Law

The Supreme Court vacated the decrees of the family court denying the Department of Children, Youth, and Families' (DCYF) petition to terminate the parental rights of Parents to their child, holding that the trial justice overlooked and misconceived material evidence of parental unfitness in this case.On remand, after finding the facts by clear and convincing evidence, the trial justice concluded that DCYF had failed to prove that it had made reasonable efforts to reunify Parents with their child. The Supreme Court vacated the decision below, holding (1) the record demonstrated that DCYF made reasonable efforts to reunify Parents with their child, and the trial justice was clearly wrong to conclude otherwise; and (2) contrary to the trial justice's conclusion, DCYF proved by clear and convincing evidence the statutory requirements supporting the termination of Parents' parental rights to their child. View "In re Nolan V-S" on Justia Law