Justia Rhode Island Supreme Court Opinion Summaries

Articles Posted in Personal Injury
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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

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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

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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

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The Supreme Court vacated the judgment of Supreme Court in favor of Plaintiff Wilmington Savings Fund Society, FSB in this case involving a dispute over payments due under a promissory note relating to Defendants' mortgage, holding that summary judgment was improperly granted under the terms of this case.Plaintiff's predecessor filed a complaint against Defendants alleging breach of contract. The hearing justice granted summary judgment in favor of Plaintiff. Defendants appealed, arguing that the issue of whether Plaintiff complied with the note's notice provisions was a question of material fact precluding summary judgment. The Supreme Court vacated the judgment below, holding that Plaintiff's failure to send the notice of default to the property address referred to in the note was not in accordance with the terms of the note, and therefore, summary judgment should not have been granted. View "Wilmington Savings Fund Society, FSB v. Cavalloro" on Justia Law

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The Supreme Court quashed the order of the superior court granting Defendant's motion for a protective order limiting the deposition testimony of Plaintiff's expert witness to causation opinions and prohibiting Plaintiff from further supplementing the expert witness's disclosure to include other opinions, holding that the trial justice erred.Plaintiff brought this medical malpractice action alleging negligence. The trial justice later granted Defendant's motion for a protective order seeking to preclude the expert witness from offering opinions regarding the standard of care and prohibited Plaintiff from supplementing the witness's disclosure to include opinions on topics outside of causation, including standard of care. The Supreme Court quashed the decision below, holding that the trial justice abused her discretion in granting Defendant's motion. View "Vecchio v. Women & Infants Hospital" on Justia Law

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The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendant in this personal injury action, holding that Plaintiff failed to establish the existence of a legal duty on the part of Defendant.Plaintiff purchased fish at Defendant's supermarket and allegedly became ill after he ate the fish. Plaintiff brought this negligence action alleging that Defendant breached its alleged duty to him to "process, prepare, cook and sell food free from unreasonably dangerous defects." The hearing justice granted summary judgment for Defendant. The Supreme Court affirmed, holding (1) there was no error in the hearing justice's ruling as regarding Defendant's duty; and (2) the hearing justice did not commit reversible error by denying Plaintiff's motion invoking Rule 56(f) of the Superior Court Rules of Civil Procedure. View "Meeks v. Stop & Shop Supermarket Co., LLC" on Justia Law

Posted in: Personal Injury
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The Supreme Court affirmed the orders of the superior court in these three related by unconsolidated appeals, holding that Appellants were not entitled to relief on their arguments on appeal.In No. 2021-303-A and No. 2021-331-A, defendants Thomas and John Mercurio appealed pro se from a superior court granting the motion to adjudge the Mercurios in contempt filed by plaintiffs Dean and Melissa Pinelli. In No. 2021-331-A, plaintiff Elena Massarone appealed pro se from a superior court order granting the Pinellis' motion to adjudge Elena in civil contempt. On appeal, Elena and the Mercurios both asserted largely identical claims of error. The Supreme Court affirmed in all cases, holding that because none of the appellants provided transcripts to the Court from any of the hearings held throughout the proceedings and because their statements failed to provide any cogent legal analysis or substantive discussion of their claims, the appellants waived their arguments on appeal. View "Pinelli v. Mercurio" on Justia Law

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In this slip-and-fall case, the Supreme Court affirmed the judgment of the superior court denying Plaintiff's motion for a new trial following a jury verdict in favor of Defendants, holding that the trial justice did not err in denying the motion.Plaintiff sued the Town of Johnson and some of its officials, alleging that Defendants were negligent in maintaining the premises of the Johnston Town Hall in a safe condition by failing to warn invitees, such as himself, of a "dangerous condition" - namely, curbing that lacked any yellow highlighting or warning. The jury returned a verdict for Defendants. Plaintiff filed a motion for a new trial, which the trial justice denied. The Supreme Court affirmed, holding that the trial justice (1) did not err in instructing the jury as to the element of duty; (2) Defendant waived his second claim of instructional error; and (3) the trial justice did not err by concluding that expert testimony was required to establish that the angle of the curb constituted a dangerous condition. View "Mangiarelli v. Town of Johnston" on Justia Law

Posted in: Personal Injury
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The Supreme Court affirmed the judgment of the superior court in favor of Defendants and dismissing this suit in accordance with Sup. Ct. R. Civ. P. 37, holding that dismissal was warranted in this case.Plaintiff filed this action against Defendants, St. Thomas More Catholic Church, St. Peter's By-the-Sea Episcopal Church, and the Roman Catholic Bishop of Providence alleging that the excessive notice emanating from Defendants' bell towers was a nuisance and seeking more than $30 million in damages. The trial justice ultimately granted Defendants' motion to dismiss based on Plaintiff's answers to interrogatories, including an interrogatory requiring him to identify any expert witness he expected to call at trial. The Supreme Court affirmed, holding that Plaintiff's failure to provide a complete discovery response after repeated orders and admonitions by the trial court warranted dismissal. View "Devaney v. St. Thomas More Catholic Church" on Justia Law

Posted in: Personal Injury
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The Supreme Court affirmed the judgment of the superior court ruling that Defendant did not owe a duty of care to eighteen-year-old Plaintiff at the time of an accident in a utility substation, holding that there was no error.Plaintiff was a trespasser at the substation when an accident occurred, resulting in the amputation of her left hand and a two-month hospital stay. Plaintiff brought this action alleging that Defendant, the property owner, owed a duty of care to maintain its substation in a reasonably safe condition and that, as a direct and proximate result of Defendant's negligence, Plaintiff was injured. The hearing justice granted summary judgment in favor of Defendant. The Supreme Court affirmed, holding that no duty flowing to Plaintiff from Defendant ever arose under the circumstances of this case. View "Borgo v. Narragansett Electric Co." on Justia Law

Posted in: Personal Injury