Justia Rhode Island Supreme Court Opinion Summaries

Before Decedent's death, the Department of Human Services (DHS) expended $94,162 in medical assistance payments on Decedent's behalf. Neither administratrixes of Decedent's estate notified DHS that Decedent's estate had commenced. More than three years after Decedent's death, DHS learned Decedent's estate had been opened and filed a claim out of time with the probate court, seeking reimbursement for the medical assistance payments it had paid on Decedent's behalf prior to her death. The probate court entered an order allowing the claim. The estate appealed, arguing that DHS's claim was time barred. The superior court concluded that DHS was not precluded under the statute of limitations from filing its claims for medical assistance payments and entered summary judgment in DHS's favor. The Supreme Court affirmed, holding that the statute of limitations was not triggered until the date DHS received notice that the state had been opened, and therefore, its claim was not time-barred. View "In re Estate of Manchester" on Justia Law

Plaintiffs sought permits from the City of Providence so they might restore electrical meters at the property they owned. The property was located in an area of the City that was zoned for no more than two-family dwelling units. The City conducted an inspection of the property, which revealed the property was being used as a three-family dwelling, and therefore, it was not in compliance with zoning ordinances. Plaintiffs filed an appeal of the City official's determination that their property was an illegal three-family dwelling. The zoning board affirmed. Plaintiffs appealed and sought a declaration that their use of the property was a legal nonconforming use. The trial justice denied relief. The Supreme Court affirmed, holding that the trial justice (1) did not abuse his discretion in declining to declare that Plaintiffs' property was a legal nonconforming use; (2) did not err in declining to apply the doctrine of equitable estoppel against the City; and (3) did not err in declining to allow Plaintiffs to rely upon the doctrine of laches as a basis for ruling that the City should not be permitted to enforce the provision of the zoning ordinance that prohibits using the property in a three-family manner. View "Cigarrilha v. City of Providence" on Justia Law

Plaintiff was a business agent for a labor organization that represented former employees of the public library. On June 30, the library terminated the employment of thirty-eight union employees. Plaintiff filed a complaint with the Department of Labor and Training (DLT)'s Division of Labor Standards, alleging that the library had failed to pay the employees vacation pay that the employees had accrued at the time of their termination. A hearing officer concluded that the employee's vacation time accrued on July 1 of each fiscal year, and because the employees were not employed on that date, they were not entitled to vacation pay. Plaintiff appealed, The superior court dismissed the complaint for lacking of jurisdiction, ruling that Plaintiff's complaint was untimely filed. The Supreme Court quashed the decision of the superior court and remanded, holding (1) Rule 6 of the Superior Court Rules of Civil Procedure applies to the superior court's review of administrative decisions; and (2) under Rule 6, Plaintiff's complaint would have been timely filed. Remanded. View "McAninch v. State Dep't of Labor and Training " on Justia Law

Petitioner, a sergeant with the police department, applied for accidental disability benefits for post traumatic stress disorder and anxiety disorder. The Employees' Retirement System of Rhode Island (retirement board) denied Petitioner's application. The superior court affirmed the retirement board's decision on the basis of his conclusion that the court lacked jurisdiction over the case because Petitioner failed to timely file her appeal and because the facts would not justify equitable tolling of the deadline for filing an appeal. The Supreme Court quashed the judgment of the superior court and remanded with directions that Petitioner's appeal be considered as timely pursuant to the doctrine of equitable tolling, holding that, under the circumstances of this case, the trial court abused its discretion in declining to toll the deadline. View "Rivera v. Employees' Ret. Sys. of R.I." on Justia Law

Defendants, the city zoning board of review and the members of that board voted at a February 23, 2009 meeting to approve a request for an extension of time in which to substantially complete certain improvements to property. The request was referenced in one of the items contained in the agenda posted with respect to the board's meeting. Plaintiffs alleged that the agenda item violated the Rhode Island Open Meeting Act because it was a vague and indefinite notice to the public and one lacking in specificity. The superior court granted Defendants' motion for summary judgment, finding that the agenda item provided sufficient notice and thus did not violate the Act. The Supreme Court vacated the judgment of the superior court, holding that the agenda item did not fairly inform the public of the nature of the business to be discussed or acted upon, and thus the agenda item did not comply with the standard established by the Act. Remanded for entry of summary judgment in favor of Plaintiffs with instructions that the action taken by the zoning board be declared null and void. View "Anolik v. Zoning Bd. of Review of City of Newport" on Justia Law

The Lloyds owned property abutting property owned by the Bardorfs. Both properties were zoned R-10. The Bardorfs filed an application for a special-use permit proposing the removal of a deck and an existing two-story addition on the rear of their home and the construction of an addition and a deck. The Lloyds objected to the application. The city's zoning board of review (board) granted the special-use permit. The superior court affirmed the board's decision. The Supreme Court affirmed, holding (1) the board and trial justice did not err in applying the standard governing a special-use permit to the Bardorfs' application, as the appropriate form of relief for a party seeking to expand a dimensionally noncomforming structure is a special-use permit; (2) neither the superior court nor the board erred in allowing the Bardorfs to utilize expanded lot coverage authorized by a 1992 dimensional variance; (3) because the zoning ordinance does not contemplate a calculation of building mass or three-dimensional spaces in the criteria for alterations of dimensionally noncomforming structures, the trial justice did not err in finding the addition would intensify the nonconformity associated with lot building coverage; and (4) legally competent evidence supported the trial justice's findings. View "Lloyd v. Zoning Bd. of Review for City of Newport" on Justia Law

Defendant pled guilty to eight felony counts relating to his unethical conduct as a member of the town council. On the day of his sentencing, the U.S. district court entered an order of forfeiture requiring Defendant to forfeit $46,000 to the federal government, representing the bribe money Defendant received to perform official acts as town council member. While Defendant was employed, he had contributed $30,554 to the Employees' Retirement System of Rhode Island (ERSRI). While a member of the town council, Defendant had contributed $5,490 to the Municipal Employees' Retirement System (MERS). Both ERSRI and MERS were administered by the Retirement Board of ERSRI (Board). After the Board refused to refund Defendant's contributions to ERSRI, Defendant filed a complaint against the Board, contending that the Board was obligated to return his contributions to him. The trial justice (1) revoked Defendant's MERS pension in its entirety, and (2) ordered the Board to return to Defendant the contributions he had made to ERSRI. The Supreme Court affirmed, holding that, because the federal court issued neither a judgment nor an order of restitution against Defendant, the Board had no statutory basis upon which it could refuse Defendant's demand for a return of his contributions. View "Zambarano v. Ret. Bd. of Employees' Ret. Sys. of R.I." on Justia Law

Plaintiff was injured while he was working for Defendant. Plaintiff began receiving partial disability benefits. Several years later, Plaintiff was notified that his benefits would be terminated. Plaintiff filed a petition requesting continuation of his benefits and/or a finding that he was totally disabled. After a trial, the workers' compensation court (WCC) denied the petition. The appellate division of the WCC affirmed. The Supreme Court granted Plaintiff's petition for a writ of certiorari and affirmed, holding (1) Plaintiff was not entitled to partial incapacity benefits because, contrary to Plaintiff's position, his failure to regain his earning capacity did not constitute a "material hinderance" to his finding employment suitable to his limitations within the meaning of R.I. Gen. Laws 28-33-18.3(a)(1); and (2) section 28-33-18 does not violate the equal protection clause of the Rhode Island Constitution. View "Nichols v. R&D Constr. Co." on Justia Law

Two enforcement officers of the Rhode Island Department of Environmental Management (DEM) boarded a boat owned by Daniel Barlow when Barlow was not on board and allegedly discovered the amount of summer flounder Barlow caught that day was more than was permitted under the applicable regulations. A notice of violation followed. In the ensuing litigation, the DEM found Barlow ineligible to participate in its 2010 Summer Flounder Sector Allocation Pilot Program because of a previous consent agreement he had entered into with the department. The agreement reflected a settlement of the allegation that Barlow violated a state marine fisheries regulation for catch limits. The Administrative Adjudication Division of DEM reversed, finding the consent agreement was not an administrative penalty because it absolved Barlow of all liability arising from the alleged violation. The superior court reversed. The Supreme Court quashed the decision of the superior court and found in favor of Barlow, holding that DEM wrongly used the consent agreement as a reason to bar him from the program. View "State Dep't of Envtl. Mgmt. v. Admin. Adjudication Div." on Justia Law

Plaintiff, who was employed as a school bus driver, broadcasted that the bus she was driving, which was full of elementary-school children, had been struck by gunfire and that panic had spread among the children. Displeased with the manner in which Plaintiff handled the situation, the Town of Johnson school department requested that Plaintiff no longer be assigned to transport Johnson students. Eventually, Plaintiff left her employment. Plaintiff subsequently filed suit for wrongful termination against members of the Johnson public schools (Defendants), alleging that Defendants wrongfully requested that Plaintiff be terminated from her employment. In response to the trial justice's remarks, Plaintiff moved to amend her complaint to include a claim of tortious interference, which the trial justice denied. Thereafter, the superior court granted summary judgment against Plaintiff. The Supreme Court vacated the judgment of the superior court, holding that the court abused its discretion in denying Plaintiff's motion to amend her complaint without specific findings. Remanded. View "Lomastro v. Iacovelli" on Justia Law