Justia Rhode Island Supreme Court Opinion Summaries

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

Integra is an accountable-care organization under the Medicare Shared Savings Program (MSSP). RIPCPC is an independent practice association of physicians located in Rhode Island. The plaintiffs (Hayden, King, Corsi) are primary care physicians and operated their own independent practices. Each participated in Integra until 2018, when they terminated their respective agreements upon the sale of their respective independent practices (Integra agreements) and terminated their relationships with RIPCPC. The plaintiffs alleged breach of contract, unjust enrichment, breach of the implied covenant of good faith and fair dealing, conversion, and anticipatory breach/repudiation against Integra and RIPCPC, claiming that Integra and RIPCPC owed plaintiffs certain payments and shared savings for 2017 and 2018.The defendant’s motion to dismiss was granted as to breach of the implied covenant of good faith and fair dealing by RIPCPC and anticipatory breach/repudiation by RIPCPC. RIPCPC then successfully moved to stay the proceedings and compel arbitration as to plaintiffs’ claims against RIPCPC for breach of contract, unjust enrichment, conversion, and declaratory judgment. The Rhode Island Supreme Court held that the hearing justice did not err in granting RIPCPC’s motion to compel arbitration with regard to Hayden’s claims for breach of contract, conversion, and unjust enrichment nor in granting RIPCPC’s motion to compel arbitration with regard to Corsi’s claim for breach of contract but erred in granting RIPCPC’s motion to compel arbitration with regard to Corsi’s claims and King’s claims for conversion and unjust enrichment. View "Hayden v. Integra Community Care Network, LLC" on Justia Law

The Supreme Court affirmed the order of the district court committing Respondent to a residential living facility for adults with developmental disabilities, holding that there was no error or abuse of discretion.The Rhode Island Department of Behavioral Healthcare, Developmental Disabilities and Hospitals filed a petition for civil court certification to retain Respondent, a person with developmental disabilities, in a residential facility. The hearing justice found that Respondent was developmentally disabled and ordered that he reside at a group home. The Supreme Court affirmed, holding (1) Respondent's appeal was timely; and (2) Respondent waived his argument that the district court erred in allowing the admission of testimony regarding Respondent's juvenile conviction, his requirement to register as a sex offender, and other uncharged bad acts committed by Respondent. View "In re J.T." on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of South County Hospital, Home & Hospice Care of Rhode Island and Emmy Mahoney, M.D. (collectively, Defendants), and dismissing all claims alleged by Plaintiff individually and on behalf of the Guardianship of Joyce C. Willner, holding that the trial justice did not err in dismissing the claims.Plaintiff filed an eight-count complaint against Defendants, individually and as guardian of Joyce Willner, his mother. The trial judge granted Defendants' motions to dismiss and motions for summary judgment, dismissing all claims. The Supreme Court affirmed, holding that the trial justice did not err in (1) dismissing the claims alleged by Plaintiff on behalf of the guardianship because Joyce had no right to be represented by Plaintiff, who was not authorized to practice law; and (2) denying Plaintiff's request to appoint a guardian ad litem. View "Willner v. South County Hospital" on Justia Law

The Supreme Court affirmed the postjudgment order of the family court in favor of Judith Cusick requiring Maurice Cusick to submit to limited genetic testing for the benefit of the parties' minor children, holding that the hearing justice made sufficient findings of fact and did not overlook or misconceive any evidence.Judith, Maurice's former wife, filed her motion for genetic testing after Maurice was diagnosed with a genetic heart condition that poses significant risks that can result in sudden death. The hearing justice granted the motion. Maurice appealed, arguing for the first time that ordering him to submit to genetic testing violated his constitutional rights to privacy and due process. The Supreme Court affirmed, holding (1) Maurice's constitutional challenges were not property before the Court; and (2) the hearing justice's conclusion that genetic testing was in the best interest of the children was supported by the evidence, and the order was both balanced and reasonable. View "Cusick v. Cusick" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree child abuse, holding that the trial justice did not err by requiring a licensed clinical social worker to testify about statements Defendant made to her while seeking mental-health treatment.A dispositive issue on appeal was whether any privilege arising from the Confidentiality of Health Care Information Act, R.I. Gen. Laws 5-37.3, is abrogated by R.I. Gen. Laws 40-11-11. The Supreme Court affirmed, holding (1) section 40-11-11 unambiguously abrogates all privileges that might otherwise attach to communications between any professional person and her patient in situations involving known or suspected child abuse or neglect; and (2) this nullification of such privileges in judicial proceedings includes criminal proceedings. View "State v. LeFebvre" on Justia Law

The Supreme Court quashed the judgment of the superior court that reversed a decision by the Rhode Island Department of Health (DOH) to grant Petitioner’s application for a Health Care Certificate of Need (CON) on the basis that Petitioner’s application did not demonstrate a public need.The Supreme Court disagreed, holding (1) the DOH correctly applied its rules and regulations when it determined that the public need set forth in Petitioner’s application was appropriate; and (2) the DOH relied upon competent evidence for future public need in support of its decision to grant Petitioner’s CON application. View "Endoscopy Associates, Inc. v. Rhode Island Department of Health" on Justia Law

The Supreme Court quashed the judgment of the superior court that reversed a decision by the Rhode Island Department of Health (DOH) to grant Petitioner’s application for a Health Care Certificate of Need (CON) on the basis that Petitioner’s application did not demonstrate a public need.The Supreme Court disagreed, holding (1) the DOH correctly applied its rules and regulations when it determined that the public need set forth in Petitioner’s application was appropriate; and (2) the DOH relied upon competent evidence for future public need in support of its decision to grant Petitioner’s CON application. View "Endoscopy Associates, Inc. v. Rhode Island Department of Health" on Justia Law

Plaintiffs filed this petition for the appointment of a guardian over their father. After the probate court denied Plaintiffs’ petition, Plaintiffs appealed. The superior court dismissed the complaint seeking review from the probate decision for Plaintiffs’ failure to adhere to statutory deadlines. Plaintiffs subsequently filed a motion pursuant to R.I. Gen. Laws 9-21-6 arguing that the dismissal of the probate court appeal was improper. The superior court denied the motion. The Supreme Court vacated the decision of the superior court, holding that Plaintiffs’ failure to have satisfied the requirements of R.I. Gen. Laws 33-23-1(a) constituted excusable neglect, and therefore, justice required that Plaintiffs’ appeal be allowed to proceed under section 9-21-6. View "Duffy v. Estate of Scire" on Justia Law

Plaintiffs filed suit, individually and per proxima amici, against numerous defendants, alleging, inter alia, negligence, lack of informed consent, and vicarious liability for injuries sustained by their minor daughter, Yendee, who was born with a genetic blood disorder. Four groups of defendants filed motions to dismiss on the grounds that R.I. Gen. Laws 9-1-14.1(1), an act that tolls the three-year statute of limitations for medical malpractice claims when the person claiming injury is a minor, barred Plaintiffs’ claims. The trial justice entered judgment in favor of Defendants, concluding that all of Plaintiffs’ claims were time-barred but that Yendee retained the right to bring suit on her own behalf when she reached the age of majority, and up to three years thereafter. After issuing an order to show cause, the Supreme Court (1) vacated the judgments entered in favor of defendants Corning Incorporated and Quest Diagnostics, LLC because Plaintiffs’ allegations against these defendants were not medical malpractice claims; and (2) directed that Plaintiffs’ appeal, as well as the appeals and cross-appeals of Rhode Island Hospital, Miriam Hospital, Women & Infants Hospital and each hospital’s associated medical professionals, be assigned to the Court’s regular calendar for further briefing and argument. View "Ho-Rath v. R.I. Hosp." on Justia Law