Justia Rhode Island Supreme Court Opinion Summaries

The plaintiff, Willie Gray, filed a complaint for personal injuries sustained in a fire at a multifamily residential property in Providence on January 12, 2018. The property was allegedly owned by Dexter Jackson, whose negligence was claimed to have caused the fire. The City of Providence was also named as a defendant for being aware of several housing code violations at the property from January 2015 through January 2018. The plaintiff failed to provide adequate responses to the defendant's discovery requests, leading to a motion to compel and subsequent orders to produce more responsive answers.The Superior Court granted the defendant's motion to compel and later a motion to enter final judgment against the plaintiff due to non-compliance with discovery orders. The plaintiff did not object to these motions and failed to appear at the hearing for the renewed motion for entry of final judgment. The Superior Court denied the plaintiff's subsequent motion to vacate the order granting final judgment, citing a lack of objection and failure to comply with discovery requirements.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's order. The Court found that the plaintiff had ample opportunity to comply with discovery obligations and failed to do so. The trial justice did not abuse his discretion or commit an error of law in denying the plaintiff's motion for relief. The appeal was considered interlocutory, but the Court proceeded to evaluate the merits due to the futility of remanding for default judgment against Jackson, who had not participated in the litigation. The order of the Superior Court was affirmed. View "Gray v. City of Providence" on Justia Law

The plaintiffs, Jason Blouin and Heather Blouin, filed a medical malpractice lawsuit against several healthcare providers, alleging negligence in the births of their children, X.B. and D.B., who were born with cystic fibrosis. Heather Blouin received prenatal care from University OB-GYN, but was not offered genetic screening or counseling. X.B. was born in 2009 and later exhibited symptoms of cystic fibrosis, but was not diagnosed until 2013. D.B. was born in 2012 and was diagnosed with cystic fibrosis shortly after birth. The plaintiffs claimed that the healthcare providers' failure to diagnose and inform them of the genetic risks led to the births of X.B. and D.B. with cystic fibrosis.The Superior Court granted summary judgment in favor of the pediatric defendants, ruling that they did not owe a duty of care to the parents. The court also granted partial summary judgment in favor of the obstetric defendants, dismissing the wrongful-life claims based on the Rhode Island Supreme Court's decision in Ho-Rath v. Corning Incorporated, which held that no duty is owed to a child born with defects due to negligence in genetic counseling.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's decision. The Court held that the pediatric defendants did not owe a duty to the parents to diagnose X.B. with cystic fibrosis for the purpose of informing their reproductive decisions. The Court also upheld the dismissal of the wrongful-life claims, reiterating that life with impairments does not constitute a legally recognized injury under Ho-Rath III. The Court concluded that the trial justice correctly applied the law and that the plaintiffs' claims failed as a matter of law. View "Blouin v. Koster" on Justia Law

The case revolves around a plaintiff, Carol Allen, who slipped and fell on the steps of Newport City Hall during a winter storm, resulting in severe injuries. Allen alleged that the city and its employees were negligent in failing to properly treat the stairs for adverse weather conditions. The case was heard in the Superior Court, where the trial justice ruled in favor of Allen, finding that the city and its employees had a duty to clear the steps of snow and ice, even during an ongoing storm, due to "unusual circumstances."The city and its employees appealed the decision to the Supreme Court of Rhode Island. They argued that the trial justice erred in not applying the "Connecticut Rule," which states that a property owner's duty to clear snow and ice does not arise until a reasonable time after a storm has ended. The city argued that the storm was ongoing at the time of Allen's fall, and therefore, they did not owe her a duty to clear the steps.The Supreme Court of Rhode Island agreed with the city and its employees. The court found that the trial justice had erred in applying the "unusual circumstances" exception to the Connecticut Rule. The court clarified that "unusual circumstances" exist when a property owner's actions exacerbate the inherent risk of traveling during a storm, not when the owner fails to alleviate the danger. In this case, the city and its employees did not engage in any behavior that increased the risk to Allen. Therefore, the court vacated the judgments of the Superior Court and remanded for entry of judgment in favor of the city and its employees. View "Allen v. Sitrin" on Justia Law

The plaintiff, Gail M. McCormick, filed a personal injury lawsuit against Narragansett Improvement Company, Inc. (NICO) for injuries she sustained in a motorcycle accident on May 29, 2010. McCormick alleged that she lost control of her motorcycle due to unguarded manhole covers on a road in Cranston, Rhode Island, which NICO was contracted to repair. NICO failed to respond to the lawsuit, and a default judgment was entered against them on November 18, 2011. However, NICO later sought to vacate the default judgment, arguing that they had not begun repairs on the road until after the accident occurred.The Superior Court granted NICO's motion to vacate the default judgment. The case proceeded to a seven-day jury trial in March 2022, which resulted in a verdict in favor of NICO. McCormick subsequently filed a motion for a new trial, which was denied by the trial justice.McCormick appealed to the Supreme Court of Rhode Island, arguing that the Superior Court erred in vacating the default judgment and in denying her motion for a new trial. The Supreme Court found that the Superior Court had abused its discretion in vacating the default judgment without requiring NICO to provide evidence explaining their failure to respond to the lawsuit. The Supreme Court therefore vacated the judgment of the Superior Court and remanded the case for a hearing on the assessment of damages. View "McCormick v. Narragansett Improvement Company, Inc." on Justia Law

This case involves a medical negligence claim brought by John Armour, individually and as personal representative of the Estate of Judith Armour, against David Bader, M.D., Neil Brandon, M.D., and South County Hospital Healthcare System d.b.a. South County Cardiology. The plaintiff alleges that the defendants negligently failed to provide adequate follow-up and treatment to Judith Armour following a stress test, which ultimately led to her death from a heart attack the next day. The stress test results were "markedly abnormal" and indicated potential significant coronary artery disease, but Mrs. Armour was sent home after the staff determined she was medically stable.The case was tried in the Washington County Superior Court. The jury heard testimony from various witnesses, including the nurses, the defendant-doctors, Mrs. Armour’s family, and expert testimony from both sides regarding the applicable standard of care and causation. The jury returned a verdict in favor of the defendants on all counts. The plaintiff filed a motion for a new trial, arguing that the jury’s verdict was against the fair preponderance of the evidence and that the trial justice erred in several respects. The trial justice denied the motion, concluding that the overwhelming weight of the evidence supported the jury’s verdict.On appeal to the Supreme Court of Rhode Island, the plaintiff argued that the trial justice erred in refusing to issue a jury instruction based on a previous court decision, erred in permitting defendants’ standard-of-care expert to utilize the referring doctor’s records, and erred in limiting cross-examination of that expert regarding a particular study. The Supreme Court found that the trial justice's refusal to issue the requested jury instruction was prejudicial and constituted reversible error. The court also found that it was an error to allow the expert to use the referring physician’s records to support his opinions as defendants did not have access to this information when determining if Mrs. Armour was stable. Lastly, the court concluded it was an abuse of discretion to limit cross-examination on a point that went to the heart of the most important standard-of-care issue in the case. The judgment of the Superior Court was vacated and the case was remanded for a new trial. View "Armour v. Bader" on Justia Law

The case revolves around a plaintiff, Carol Allen, who slipped and fell on the steps of Newport City Hall while exiting the building after paying her property taxes. At the time of the incident, there was light to moderate snowfall, and the steps were covered with a slushy film. Allen suffered a severe head injury as a result of the fall, which led to multiple seizures and the loss of her ability to taste and smell. She filed a negligence lawsuit against the city and its employees, alleging they failed to properly treat the stairs for adverse weather conditions.The Superior Court ruled in favor of Allen, finding that the city and its employees had a duty to clear the steps of snow and ice, even during an ongoing storm, due to the unusual circumstances of the case. The court found that the city's failure to apply ice melt and take other protective measures exacerbated the risks inherent in using the stairs during a storm. The court also found that Allen was 35 percent comparatively negligent for her fall.The city and its employees appealed the decision to the Supreme Court of Rhode Island. The Supreme Court vacated the judgments of the Superior Court, ruling that the city and its employees did not have a duty to clear the steps until a reasonable time after the storm had ended. The court found that the city's failure to take precautionary measures did not exacerbate the risks already inherent in traveling during a storm. Therefore, the court concluded that there were no unusual circumstances that triggered the city's duty prior to the end of the storm. The case was remanded for entry of judgment in favor of the city and its employees. View "Allen v. Sitrin" on Justia Law

The plaintiff, Dania Mateo, filed a case against Davidson Media Group Rhode Island Stations, LLC and several of its employees, which included 22 counts alleging violations of Rhode Island's Fair Employment Practices Act (RIFEPA) and Civil Rights Act (RICRA) as well as claims of sexual harassment, civil conspiracy, intentional infliction of emotional distress, negligent infliction of emotional distress, assault and battery, negligence, false imprisonment, defamation, and conspiracy to commit defamation. The case was pending for nearly 14 years.Mateo appealed a Superior Court decision granting partial summary judgment in favor of certain defendants. The defendants cross-appealed, arguing that the hearing justice erred in granting partial final judgment because he failed to make an express determination that there was no just reason for delay, as required by Rule 54(b) of the Superior Court Rules of Civil Procedure.The Supreme Court of Rhode Island found the defendants’ cross-appeal meritorious. The Court ruled that the hearing justice erred in granting partial final judgment because he failed to determine whether the criteria clearly set forth in Rule 54(b) had been satisfied. The Court held that the judgment must be vacated and the case remanded to the Superior Court for further proceedings. As a result, the Court did not reach the issues raised in the plaintiff's appeal. View "Mateo v. Davidson Media Group Rhode Island Stations, LLC" on Justia Law

This case arises from an automobile accident involving Lauren Barnes and Nancy Hodys, where both parties sustained serious injuries and neither has any memory of the accident. A syringe was found in Barnes' car and her urine later tested positive for opioids and benzodiazepines. Barnes filed a complaint against Hodys alleging her negligence caused the collision, while Hodys filed a complaint against Barnes alleging her negligence and intoxication caused the accident.Barnes engaged Dr. David M. Benjamin as an expert witness, who concluded that it was "not possible to determine" whether Barnes' post-accident impairment was caused by head trauma, controlled substances, or medication. However, during deposition, Dr. Benjamin changed his previous opinion, stating that a combination of drugs and brain injury was the most likely explanation for Barnes' impairment. After the deposition, Barnes' counsel learned that Dr. Benjamin had a type of cancer, which along with the medication he was taking, caused him confusion, memory issues, and fatigue. Barnes then filed a motion to replace Dr. Benjamin due to his medical unavailability, which was denied by the lower court.The Supreme Court of Rhode Island found that the trial court erred by not providing a rationale for its decision denying Barnes' motion to modify the scheduling order and replace her expert witness. The Supreme Court held that a reasoned exercise of discretion requires some explanation, which was not provided in this case. Therefore, the court quashed the order of the lower court and remanded the case back to that tribunal with instructions to conduct a meaningful analysis of the issues raised, consistent with the Supreme Court's opinion. View "Barnes v. Hodys" on Justia Law

In this case, the plaintiff, Jordan Nissensohn, as the administrator of the Estate of Michael Nissensohn, filed a suit against University Medical Group (UMG), Dr. Alan Epstein, and Dr. Steven Sepe, alleging numerous claims including defamation, breach of contract, tortious interference with contractual relations, conversion, and violations of the Rhode Island Whistleblowers’ Protection Act (RIWPA). The Superior Court entered a judgment in favor of the defendants, granting summary judgment.The plaintiff, Dr. Michael Nissensohn, had been employed as a gastroenterologist by UMG and was supervised by Dr. Epstein. The plaintiff had a series of disagreements and conflicts with Dr. Epstein over teaching responsibilities and alleged discrepancies in teaching compensation. The plaintiff also claimed that Dr. Epstein had disclosed his mental health information to another staff member, and had spread a rumor about his mental health. Additionally, the plaintiff claimed that Dr. Epstein interfered with his prospective business relations with patients and his contract, and converted his personal laptop.The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. The court held that the plaintiff did not demonstrate that he engaged in protected conduct under the RIWPA because he did not report actual violations of the law. The court also ruled that the plaintiff's defamation claim abated upon his death and therefore did not survive. Regarding the breach of contract claim, the court found that the plaintiff failed to provide evidence of a breach of the written agreement. The court further held that the plaintiff failed to show that Dr. Epstein intended to harm his contract, which was an essential element of his claim for tortious interference. Lastly, the court found that the plaintiff failed to provide any non-hearsay evidence to prove his demand and refusal, thus failing to establish his claim for conversion. View "Nissensohn v. CharterCARE Home Health Services" on Justia Law

The Supreme Court quashed the decision of the superior court granting Defendant's motion to compel production of a complete, unreacted copy of a settlement agreement between Plaintiffs and the former codefendants who settled Plaintiffs' claims, holding that the trial justice abused her discretion in granting Defendant's motion.In granting Defendant's motion to compel production, the trial justice concluded that the amount paid in accordance with the settlement agreement was not discoverable "pursuant to Rhode Island and federal law." When Plaintiffs failed to comply with the order the superior court granted Defendant's motion to dismiss. The Supreme Court quashed the decision below and remanded the case, holding that the trial justice abused her discretion in granting Defendant's motion to compel production of a complete, unreacted copy of the settlement agreement. View "Noonan v. Sambandam" on Justia Law