Justia Rhode Island Supreme Court Opinion Summaries

Carel Bainum was found guilty of willful trespass because of her unwelcome contact with a former resident in the dementia ward of the Coventry Health and Rehabilitation Center. Bainum then brought a civil action against the Coventry Police Department, alleging that her willful trespass conviction was the consequence of two malicious acts by the Department. The motion justice granted summary judgment in favor of the Department. The Supreme Court affirmed, holding that summary judgment was proper because Plaintiff’s malicious prosecution claim failed as a matter of law, and therefore, her civil-conspiracy claim must also fail. View "Bainum v. Coventry Police Department" on Justia Law

Jason Goffe and Michael Petrarca were high-speed racing when Goffe lost control of his vehicle and whirled into the eastbound lane. William Walmsley struck Goffe’s vehicle, killing Goffe and his passenger, Brendan O’Connell Roberti. Roberti’s parents (Plaintiffs) sued several defendants, including Walmsley. Because of settlement releases, Walmsley was the sole defendant who advanced to trial. A jury found Walmsley negligent and that his negligence was a proximate cause of Roberti’s death. Defendant moved for judgment as a matter of law, which the trial justice granted. Plaintiffs moved for a new trial and requested an additur to $250,000. The trial justice ruled conditionally that, if Defendant’s motion for judgment as a matter of law was overturned on appeal, he would grant Plaintiffs’ motion for additur. The Supreme Court vacated the superior court’s judgment and remanded for additional proceedings. On remand, Plaintiffs sought judgment against Walmsley for $250,000 per the additur. The hearing justice granted summary judgment for Defendant, finding that because Plaintiffs settled their claims against Goffe and Petrarca in the amount of $395,000, there was no basis for holding Walmsley individually liable for $250,000. The Supreme Court affirmed, holding that the Wrongful Death Act is subject to joint and several liability principles. View "O’Connell v. Walmsley" on Justia Law

Lend Lease (US) Construction was the general contractor on a project, and Rossi Electric Company, Inc. was a subcontractor. An employee of Rossi’s subcontractor was injured while working on the project and filed a negligence claim against Lend Lease. Lend Lease filed a third-party complaint against Rossi, alleging that, under the terms of a contract between the parties, Rossi was required to defend and indemnify Lend Lease. The superior court entered an order granting summary judgment for Rossi. The Supreme Court vacated the judgment of the superior court, holding that issues of material fact remained to be determined, and therefore, this case was not ripe for summary judgment. Remanded. View "Walsh v. Lend Lease (US) Construction" on Justia Law

Plaintiff Carmen Rohena, as parent and natural guardian of Josue Espinal, brought suit against Defendant, the City of Providence, to recover damages for injuries that Josue suffered while participating in a baseball game at Corliss Park, which was owned by Defendant. Defendant filed a motion to summary judgment, arguing that it was not liable pursuant to the Recreational Use statute. The superior court granted the motion for summary judgment. The Supreme Court affirmed, holding that Plaintiff’s argument that Defendant’s conduct fell outside the scope of the Recreational Use Statute because the City willfully or maliciously failed to guard or warn against a known dangerous condition was not properly preserved for appeal. View "Rohena v. City of Providence" on Justia Law

A two-vehicle collision resulted in one of the automobiles striking Plaintiff while she was standing at her post as a crossing guard. Plaintiff sustained severe bodily injuries from the accident. Plaintiff filed suit against the two drivers, Chicara Alston and Rick Ford, alleging that each was negligent. As relevant to this appeal, the hearing justice granted Ford’s motion for summary judgment. Plaintiff appealed, arguing that the hearing justice erred when he concluded that there were no genuine issues of material fact in dispute. The Supreme Court vacated the judgment of the superior court, holding that the elements of the negligence claim were inappropriately treated as a matter of law because the facts suggested more than one reasonable inference, and therefore, summary judgment was inappropriately granted. View "Williams v. Alston" on Justia Law

Plaintiffs filed a complaint asserting that Defendants had caused contaminants to flow onto their property. Plaintiffs then filed amended complaints asserting claims for continuing trespass, public and private nuisance, and federal and state environmental regulations. The jury rendered a verdict in favor of Plaintiffs. Plaintiffs, nonetheless, appealed from adverse rulings in Defendants’ favor. The Supreme Court affirmed in part and vacated in part the judgment of the superior court, holding (1) the trial justice erred when she impermissibly limited the testimony of Plaintiffs’ expert; and (2) the trial justice abused her discretion in imposing sanctions against Attorney Brian Wagner. Remanded for a new trial on all issues with the exception of the prayer for injunctive relief. View "Paolino v. Ferreira" on Justia Law

After Deborah Bates-Bridgmon fell at Roch’s Market in West Warwick, Deborah and her husband, Jackie Bridgmon (together, Plaintiffs), filed suit against Defendant, Roch’s Market, for injuries Deborah sustained from her fall. The jury rendered a verdict for Defendants. The Supreme Court affirmed, holding (1) the trial justice did not err by denying Plaintiffs’ motion for a new trial; (2) the trial court did not err by not instructing the jury on the “mode of operation” theory; and (3) this Court declines to consider the merits of adopting the mode of operation theory in light of the circumstances presented in this case. View "Bates-Bridgmon v. Heong’s Market, Inc." on Justia Law

Plaintiff was injured on property owned by two individual owners. The unit owners together formed The 18-20 Woodland Court Condominium Association (Defendant). Just prior to the expiration of the relevant three-year statute of limitations, Plaintiff filed a complaint against the individual unit owners, as well as an entity referred to as “XYZ Company.” Nearly an entire year after the expiration of the statute of limitations, Plaintiff sought leave to file an amended complaint in order to add Defendant as a defendant. A hearing justice granted summary judgment in favor of Defendant, concluding that the statute of limitations had run and that Plaintiff’s original complaint had not tolled the statute of limitations because Plaintiff knew of Defendant’s identity at the time she filed the complaint. The Supreme Court affirmed, holding that the statute of limitations on her claim was not tolled pursuant to R.I. Gen. Laws 9-5-20 because Plaintiff knew the identity of Defendant before the statutory period expired. View "Garant v. Winchester" on Justia Law

Plaintiffs Michael Rose and RC&D, Inc. filed suit against Defendants Stephen Brusini and the law firm Orson & Brusini Ltd. alleging professional negligence and breach of contract. The hearing justice granted summary judgment for Defendants, concluding that there was no evidence of proximate cause linking Defendants’ alleged negligence and any damages Plaintiffs may have suffered. The Supreme Court vacated the judgment of the superior court, holding that Rose submitted sufficient competent evidence to preclude the entry of summary judgment for defendants on a question of fact relating to Defendants’ liability. Remanded. View "Rose v. Brusini" on Justia Law

Scott Cohen’s vehicle collided with the rear of Antonio Soares’s stopped vehicle because Cohen's vision was temporarily impaired by the glare from the morning sun. Cohen waved to Kris Ellinwood, a police officer who was directing traffic at the time, to approach the scene. Cohen assured Ellinwood that everyone was unharmed but did not mention the sun glare. Ellinwood was writing down information in between Cohen's and Soares's vehicles when Andrew Thornley, who did not see Cohen’s vehicle due to solar glare, struck the rear of Cohen’s vehicle, causing Ellinwood to be pinned between Cohen’s and Soares’s vehicles and crushing his legs. Ellinwood filed an action against Cohen, alleging that Cohen negligently failed to warn him of the solar glare, a dangerous condition. The superior court granted Cohen’s motion for summary judgment, concluding that the public safety officer’s rule shielded Cohen from liability. The Supreme Court affirmed, holding that the public-safety officer’s rule barred Ellinwood’s negligence claim as a matter of law because Ellinwood could have reasonably foreseen that he could be struck and injured by another vehicle while coming to Cohen’s assistance.View "Ellinwood v. Cohen" on Justia Law