Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court quashed the decree of the Appellate Division of the Workers' Compensation Court (WCC) awarding attorneys' fees and costs to Petitioner, holding that the WCC's Appellate Division acted in excess of its statutory authority in concluding that R.I. Gen. Laws 45-21.2-9 conferred authority to award attorneys' fees in this case.Petitioner, a firefighter with the City of Woonsocket, sustained a work-related injury and applied for accidental disability retirement (ADR) benefits with Respondent, Municipal Employees' Retirement System of Rhode Island. Respondent denied Petitioner's ADR application, finding that Petitioner had failed to prove that is injury arose out of and in the course of his duties as a firefighter. On appeal, the trial judge granted Petitioner's petition seeking ADR benefits and awarded a counsel fee to Petitioner's counsel. The Appellate Division upheld the fee award and imposed an additional fee for counsel's work before the Appellate Division. The Supreme Court reversed, holding that the General Assembly has not conveyed specific statutory authority upon the WCC to award attorneys' fees and costs in successful ADR appeal claims. View "Koback v. Municipal Employees' Retirement System of R.I." on Justia Law

In this negligence action arising from a slip and fall on an icy sidewalk the Supreme Court affirmed the final judgment of the superior court granting summary judgment in favor of Defendants, holding that the grant of summary judgment was proper.Plaintiff had a reservation at The Old Canteen restaurant. As she approached the restaurant on the public sidewalk she fell and sustained injuries due to the icy condition of the sidewalk in that area. Plaintiff brought this complaint alleging that Defendants - The Old Canteen, Inc. and Canteen Realty, LLC - had a duty to maintain the sidewalk area and its adjacent curbing in a safe and proper condition. Defendants moved for summary judgment arguing that they did not owe Plaintiff a duty with respect to the city sidewalk upon which she fell. The trial justice granted the motion for summary judgment. The Supreme Court affirmed, holding that summary judgment was correctly granted in favor of Defendants. View "Lowney v. Canteen Realty, LLC" on Justia Law

In this negligence action, the Supreme Court affirmed the judgment of the superior court in favor of Defendant, the Narragansett Electric Company, holding that a public utility generally owes no common law duty to individual third parties who are allegedly injured, at least in part, as a result of inoperable streetlights.George Lapriocina was walking across a street at an intersection when he was struck by a motor vehicle operated and owned by Defendants. Plaintiff commenced a negligence action alleging that the area where the accident occurred was not properly illuminated at the time of the incident, creating a dangerous condition to pedestrians. The trial justice ultimately concluded that Defendant did not owe a duty of care to George. The Supreme Court affirmed, holding that Narragansett did not owe a legal duty to George, a pedestrian, to maintain the streetlight at issue. View "Laprocina v. Lourie" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of the City of Warwick and the State and dismissing this negligence action for personal injuries, holding that the public duty doctrine precluded Plaintiff's claim against the State.Plaintiff was injured when his vehicle struck a pothole. The trial court granted summary judgment in favor of Defendants. Plaintiff appealed, arguing that summary judgment was improperly granted for the State because his claim was not barred by the public doctrine doctrine. The Supreme Court affirmed, holding (1) the trial justice properly found that Plaintiff's reliance on R.I. Gen. Laws 24-8-35 to establish liability was without merit; and (2) the State's failure to repair the pothole in this case was the type of discretionary governmental activity shielded from tort liability under the public duty doctrine. View "Georges v. State" on Justia Law

The Supreme Court affirmed the judgment of the superior court confirming an arbitration award in favor of Petitioner, holding that there was no error by the hearing justice in granting the motion to confirm and denying the motion to vacate the award.Respondent filed a negligence action against Petitioner after their automobiles collided. The parties submitted the matter to nonbinding arbitration, and the arbitrator concluded that Respondent failed to satisfy his burden of showing that Petitioner acted negligently. Respondent filed a motion to vacate the arbitration award, and Petitioner filed a separate petition to confirm the arbitration award. The hearing justice confirmed the award. The Supreme Court affirmed, holding that Respondent failed to overcome his burden of defeated the presumption of validity to which an arbitration award was entitled. View "Wiggins v. Pianka" on Justia Law

The Supreme Court affirmed the decision of the Retirement Board of the Employees' Retirement System of the City of Providence denying Petitioner's application for an accidental disability retirement, holding that the Board relied on legally competent evidence.Petitioner, a firefighter, injured his right shoulder while lifting a patient. After he had recovered, he sustained a second work-related injury to his right shoulder. When a doctor evaluation concluded that he could not return to working full duty Petitioner submitted an application for an accidental disability retirement. The Board denied the application. On appeal, Petitioner argued that the Board ignored the legally competent evidence before it when it denied his application for an accidental disability retirement. The Supreme Court disagreed, holding that some evidence supported the Board's decision. View "Starnino v. Employees' Retirement System of City of Providence" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Defendant in this defamation case, holding that the trial justice did not err by granting summary judgment as a matter of law.The jury returned a verdict in favor of Plaintiff on her slander claim. After the jury verdict was rendered, the trial justice granted Defendant's motion for judgment as a matter of law and, in the alternative, granted Defendant's motions for a new trial and a remittitur. The trial court granted Defendant's motion for judgment as a matter of law pursuant to rule 50 of the Superior Court Rules of Civil Procedure, concluding that Plaintiff failed to present sufficient evidence that Defendant made defamatory statements. The Supreme Court affirmed, holding that Plaintiff failed to prove that Defendant's statements were false or were made with actual malice. View "Fuoco v. Polisena" on Justia Law

The Supreme Court affirmed the judgment of the superior court against Plaintiff and in favor of Defendant with respect to claims for fraud, negligent misrepresentation, and unjust enrichment, holding that Plaintiff's appeal was not properly before the Court.Plaintiff's underlying claims seemed from a relationship between Plaintiff and Defendant. Plaintiff asserted that he and Defendant had committed to each other to be in a long-term relationship but that Defendant decided to end that relationship. Plaintiff argued that, but for Defendant's representation that they would remain together, Plaintiff would not have devoted his time, energy, and expertise to Defendant. The superior court granted summary judgment for Defendant on all counts. The Supreme Court affirmed, holding that Plaintiff's appeal was untimely. View "Paroskie v. Rhault" on Justia Law

The Supreme Court affirmed the judgment of the superior court entering summary judgment against Plaintiff and in favor of Defendants - Michael Baird, Mike's Professional Tree Services, Inc. (MPTS), and John Rossi - with respect to Plaintiff's personal injury claims, holding that the superior court did not err.This litigation arose from a serious injury that Plaintiff suffered while he was engaged as a foreman for a tree removal crew. Plaintiff filed a complaint alleging that Defendants had been negligent on the day of the accident. The central dispute between the parties on summary judgment was whether Plaintiff was employed by MPTS, as Defendants asserted, or whether Plaintiff was an employee of a related but distinct entity, as Plaintiff insisted. The hearing justice determined that MPTS was Plaintiff's employer and granted summary judgment for Defendants. The Supreme Court affirmed, holding that the hearing justice properly determined that Plaintiff was employed by MPTS and correctly granted Defendants' motion for summary judgment. View "Selby v. Baird" on Justia Law

The Supreme Court affirmed the order of the superior court granting summary judgment in favor of Gonsalves-Pastore Realty, LLC and dismissing Mauro Poletti's negligence complaint, holding that summary judgment was properly granted.Poletti entered into an agreement with Linda Glynn, a licensed real estate agent, to assist him in the purchase of real estate for investment purposes. Later, Glynn granted two mortgages on property purchased in furtherance of Poletti's investment plan and used the resulting funds in contravention of that plan. In his complaint, Plaintiff alleged that Gonsalves-Pastore, as Glynn's employer or principal, breached its fiduciary duty to Poletti to oversee Glynn such that Glynn was acting in the best interests of Poletti and that no loss would ever occur to Poletti. The hearing justice granted summary judgment for Gonsalves-Pastore. The Supreme Court affirmed, holding that the hearing justice did not err in (1) determining that no genuine issue of material fact remained as to whether or not a fiduciary relationship existed between Poletti and Gonsalves-Pastore; and (2) concluding that no genuine issue of material fact existed as to whether or not Defendant was liable for Glynn's alleged acts of malfeasance. View "Poletti v. Glynn" on Justia Law