Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court quashed the order of the district court granting the motion to dismiss filed by the State of Rhode Island, acting by and through the Division of Taxation (Division), in this appeal stemming from a series of transactions for the purchase and sale of gasoline, holding that the district court erred in granting the Division's motion to dismiss based on Plaintiff's failure to exhaust its administrative remedies.The tax at issue was levied on a transaction between Plaintiff and another party and was the subject of several transactions between various entities. Plaintiff reimbursed a third-party for the tax assessed on the sale of 300,000 barrels of gasoline and then initiated this action alleging constitutional violations and violations of the Motor Fuel Tax. The trial judge dismissed the case for Plaintiff's failure to exhaust administrative remedies. The Supreme Court reversed, holding that the trial judge erroneously dismissed the action based on Plaintiff's failure to exhaust its administrative remedies. View "Gunvor USA, LLC v. State, ex rel. Division of Taxation" on Justia Law

The Supreme Court vacated the judgment of the superior court in favor of Defendant, in his capacity as the finance director/treasurer for the Town of Smithfield, in this action challenging the calculation of a former employee's retirement benefits, holding that the court erred in concluding that Plaintiff had failed to exhaust his administrative remedies.Armand Beaudry worked as a firefighter for the Town for several years before he was placed on disability retirement benefits. The retirement benefits were governed by a pension system that constituted "an amalgamation of various documents." The case arose from a dispute over the calculation of Beaudry's benefits. Beaudry filed a complaint challenging the amount. The trial court granted the Town's motion for summary judgment based on failure to exhaust administrative remedies. The Supreme Court vacated the judgment, holding that the hearing justice erred by finding that a challenged amendment to the plan was enforceable at the time of Beaudry's retirement, thus creating an administrative remedy that Beaudry failed to exhaust. View "Beaudry v. Rossi" on Justia Law

The Supreme Court affirmed the order of the superior court entering a preliminary injunction enjoining the enforcement of certain amendments to the New Shoreham General Ordinance, entitled Motorized Cycle Rental, holding that the hearing justice did not err in her decision granting in part Plaintiff's motion for preliminary injunction.Plaintiffs, businesses in the Town of New Shoreham that rented mopeds, filed a complaint against the Town requesting declaratory and injunctive relief and alleging that the Town had attempted to amend the ordinance at issue in contravention of a settlement agreement reached by the parties and in contravention of Mass. Gen. Laws ch. 31-19.3-5. the hearing justice granted Plaintiffs' motion to enjoin preliminarily enforcement of the amendments. The Supreme Court affirmed, holding that Plaintiffs were not entitled to relief on their allegations of error. View "Finnimore & Fisher Inc. v. Town of New Shoreham" on Justia Law

The Supreme Court vacated the judgment of the superior court affirming the determination of the Rhode Island-Sex Offender Board of Review that Petitioner posed a level II, moderate risk of reoffense, holding that the trial justice erred in upholding the Board's classification of petitioner at a level II risk to reoffend.On appeal, Petitioner argued that the trial justice erred in finding that the State presented a prima facie case sufficient to justify the Board's determination that he posed a level II, moderate risk to reoffend. The Supreme Court agreed and vacated the judgment below, holding that the evidence presented by the State was insufficient to support the Board's moderate risk classification. View "State v. Decredico" on Justia Law

The Supreme Court set aside the decision of the Rhode Island Office of the Attorney General denying Appellant's application to renew his concealed or open-carry license pursuant to R.I. Gen. Laws ch. 11-47-18(a), holding that the Attorney General's decision was not based on legally competent evidence.Police officers arrested Appellant for misdemeanor simple assault after an incident involving Appellant's firearm at his place of business. Based on this charge, the Attorney General revoked Appellant's license to carry concealed weapons. While the government eventually dismissed the charge against him Appellant's subsequent application to renew his concealed-carry license was denied by the Attorney General. The Supreme Court remanded the case, holding that there was no legally competent evidence to support the Attorney General's decision. View "Montaquila v. Neronha" on Justia Law

The Supreme Court dismissed the Episcopal Diocese or Rhode Island's challenge to an order of the Rhode Island Public Utilities Commission (PUC) that permitted the Narragansett Electric Company to charge the diocese for electricity transmission costs associated with a proposed solar development project on diocese property in Glocester, holding that the matter was moot.On appeal, the diocese argued that the PUC's order was unlawful and unreasonable for several reasons, including the assertion that the PUC subjected the diocese to a biased proceeding in violation of state law. After the Supreme Court remanded the matter to the PUC for consideration of newly discovered evidence Narragansett determined that the diocese was not subject to the challenged interconnection costs. The Supreme Court declined to address the merits of the diocese's appeal, holding that the matter was moot. View "In re Petition of the Episcopal Diocese of R.I. for Declaratory Judgment" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Defendant, in her capacity as the Town of Lincoln's tax assessor, holding that Plaintiff was not entitled to relief on its claims of error.Plaintiff brought this action arguing that Defendant (1) illegally increased the value of Plaintiff's property in light of a solar energy development on a portion of Plaintiff's property for tax years 2019 and 2020, and (2) improperly created a new tax classification not recognized by R.I. Gen. Laws 44-5-11.8(b). The superior court granted judgment in favor of Defendant. The Supreme Court affirmed, holding (1) there was no error in including the presence of a solar energy development as an element of value assessed to real property; and (2) Plaintiff's claim that the tax assessor effectively created a new tax classification for property upon which a solar energy development is located, in contravention of R.I. Gen. Laws 44-5-11.8(b), was unpersuasive. View "Polseno Properties Management, LLC v. Keeble" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Plaintiff, Key Corporation, holding that Defendant, Greenville Public Library, was not entitled to relief on its two claims of error.Plaintiff filed a complaint seeing a declaratory judgment that Defendant violated the Access to Public Records Act (the APRA), R.I. Gen. Laws 1956 chapter 2 of title 38, and seeking an order directing Defendant to produce requested records pursuant to the APRA. Plaintiff argued that Defendant was a quasi-municipal corporation that received seventy percent of its funding from the Town of Smithfield and therefore was a "public body" or "agency" as defined by the APRA. The hearing justice determined that Defendant was a public body subject to the APRA and accordingly granted Plaintiff's motion for partial summary judgment. The Supreme Court affirmed, holding that the hearing justice (1) did not err in determining that Defendant was a public body; and (2) acted within his discretion in awarding fees and costs. View "Key Corp. v. Greenville Public Library" on Justia Law

The Supreme Court affirmed the decision of the Public Utilities Commission (PUC) denying the petition for a declaratory judgment filed by Block Island Power Company (BIPCo), holding that there were no grounds to overturn the PUC's decision.In 2009, the legislature enacted R.I. Gen. Laws 39-26.1-7 (the enabling act) authorizing the Town of New Shoreham Project. In 2017, BIPCo sought a declaratory judgment declaring that the enabling act required the costs for BIPCo's interconnection facilities and backup transformer to be socialized across all electric ratepayers in the state, not just those in the Town. The PUC issued a judgment against BIPCo. The Supreme Court affirmed, holding that the PUC's reading and application of the statute was without error. View "In re Block Island Power Co. Petition for Declaratory Judgment" on Justia Law

In this real property dispute, the Supreme Court affirmed the judgment of the superior court for Defendants following the court's grant of summary judgment in favor of Defendants, holding that the trial justice did not err in ruling that the disputed land was a paper street and in finding that Plaintiff had failed to exhaust his administrative remedies.Plaintiff filed this action seeking a declaratory judgment that certain property was a public road that ran to the boundary of Plaintiff's property and that Plaintiff had the right to use the full length of the property and the right of access to his property. The superior court granted summary judgment for Defendants. The Supreme Court affirmed, holding that Plaintiff failed to exhaust his administrative remedies. View "Davis v. Town of Exeter" on Justia Law