Articles Posted in Rhode Island Supreme Court

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After a jury trial, Defendant was convicted of two counts of first-degree child molestation and five counts of second-degree child molestation. Defendant appealed, arguing, among other things, that the trial justice erred in admitting evidence that Defendant also allegedly molested the complainant's sister. The Supreme Court affirmed, holding (1) the trial justice did not abuse his discretion in admitting evidence of Defendant's other sexual misconduct; (2) the trial justice did not clearly err in denying Defendant's motion for a new trial; and (3) the trial justice correctly denied Defendant's request for new counsel prior to sentencing. View "State v. Mitchell" on Justia Law

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Plaintiff sued Defendant for negligence after the vehicles the parties were driving collided in an intersection. A jury found that Plaintiff had not proven, by a fair preponderance of the evidence, that Defendant was negligent. The trial court subsequently granted Plaintiff's motion for a new trial, concluding that, based on the testimony of the independent fact witnesses and other evidence, the court's instructions were not properly understood or applied by the jury. The Supreme Court affirmed the order granting Plaintiff's motion for a new trial, holding that the trial justice had a sufficient basis to find that the jury's verdict did not respond to the evidence, did not overlook or misconceive material facts, and was not clearly wrong in granting Plaintiff's motion for a new trial View "Gomes v. Rosario" on Justia Law

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A stone wall demarcated the boundary between Plaintiff's and Defendant's property. After Plaintiff discovered that a large portion of the stone wall had been destroyed and a significant number of trees on his property were missing, Plaintiff sought to recover damages from Defendant for the unauthorized removal of his trees and the theft of portions of the stone wall. After a jury trial, the trial court granted judgments as a matter of law in Defendant's favor. The Supreme Court vacated the judgment of the superior court and remanded for a new trial, holding (1) the trial justice abused her discretion in precluding expert testimony on the subject of historic stone walls, and the exclusion constituted reversible error; and (2) the trial justice committed prejudicial error in granting a judgment as a matter of law in Defendant's favor. View "Morabit v. Hoag" on Justia Law

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After a jury trial, Defendant was convicted of kidnapping of a minor and reckless driving. Defendant appealed, arguing that the trial justice erred in admitting testimony about the alleged sexual assault of the kidnapping victim and in denying Defendant's motion for a new trial. The Supreme Court affirmed, holding (1) because the trial justice considered the potential effects of unfair prejudice and confusion of the issues and acted accordingly by issuing limiting instructions to the jury during the trial, the justice did not abuse her discretion in admitting the evidence of the sexual assault; and (2) the trial justice did not overlook or misconceive material evidence and was not otherwise clearly wrong in denying Defendant's motion for a new trial. View "State v. Clay" on Justia Law

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After a jury trial, Defendant was convicted of first-degree murder, discharging a firearm while committing a crime of violence, and entering a dwelling with the intent to commit a larceny therein. The convictions were affirmed on appeal. Defendant subsequently filed a motion for a new trial, claiming that newly discovered evidence revealed a cooperation agreement between the police and a prominent state's witness in Defendant's murder trial and that the prosecution violated Defendant's due process rights by failing to disclose the full extent of the agreement. The superior court denied the motion. The Supreme Court affirmed, holding (1) the trial court did not err in finding that the alleged newly discovered evidence failed the first prong of the test to be applied for motions based on newly discovered evidence; and (2) Defendant's due process rights were not violated because the state did not fail to disclose information regarding the cooperation agreement. View "State v. Drew" on Justia Law

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After a trial, Defendant was convicted of two counts of first-degree child molestation and two counts of first-degree child abuse on a child under the age of five. Defendant was sentenced to concurrent life sentences on the child molestation counts. The Supreme Court affirmed, holding that the trial justice did not err in denying Defendant's motion for a new trial, as that the trial justice conducted the appropriate analysis and reached the same result as the jury after considering the evidence and independently assessing the credibility of the witnesses and the weight of the evidence. View "State v. Baptista" on Justia Law

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After John and Anne had been married almost twenty years, John filed a complaint for divorce. Three years later, the parties indicated that they had reached a settlement, which obligated John to provide health insurance for Anne until she reached sixty-five years of age, with a Medicare supplement thereafter. The parties' agreement was read into the record and approved by the trial justice, who ordered it incorporated but not merged into the final divorce decree. However, the parties never executed a written agreement. John later challenged the validity of the marital settlement agreement after Anne moved to enforce the provisions of the agreement respecting John's obligation to pay for health insurance. The family court found that the parties clearly agreed that John was to cover Anne with her health insurance and ordered John to obtain and maintain the health insurance pursuant to the agreement. The Supreme Court affirmed, holding that the agreement was sufficient to form a nonmodifiable marital settlement agreement, and therefore, John was bound by its terms. View "O'Donnell v. O'Donnell" on Justia Law

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Plaintiff filed a complaint seeking a declaratory judgment that she possessed a prescriptive easement and an easement by implication over Defendant's property. Specifically, Plaintiff claimed that she had an easement giving her the right to use a paved driveway on Defendant's property. The trial court justice found that Plaintiff had acknowledged Defendant's superior title, that she had not occupied the disputed property with hostility and under a claim of right, that she had used the disputed property openly but not notoriously, and that she did not establish an easement by implication. The Supreme Court (1) affirmed the judgment of the superior court with respect to Plaintiff's claim of an easement by implication; but (2) vacated the judgment with respect to Plaintiff's claim of a prescriptive easement, holding that the superior court erred in finding that Plaintiff (i) had not established that she used the disputed property in a hostile manner under a claim of right, and (ii) failed to prove by clear and convincing evidence that her use of the disputed property was notorious in nature. Remanded. View "Caluori v. Dexter Credit Union" on Justia Law

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After a jury trial, Defendant was convicted of several criminal offenses, including murder, robbery, assault with a dangerous weapon, and other firearm-related counts. The Supreme Court affirmed the convictions, holding that the trial justice (1) did not err when she denied Defendant's motion for new trial and did not misconceive material evidence relating to a critical trial issue; (2) did not give confusing or unwarranted instructions to the jury; (3) did not err in denying Defendant's motion for judgment of acquittal; (4) did not commit reversible error by instructing the jury that Defendant was in custody; and (5) did not permit the excessive use of leading questions during the direct examination of the State's witnesses. Lastly, Defendant was not entitled to a new trial because certain bench conferences were not placed on the record. View "State v. Whitaker" on Justia Law

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Plaintiff was allegedly injured when he tripped and fell on a public sidewalk that was uneven and filled with cracks. Plaintiff sued the owner of the property that abutted the sidewalk and the property's tenants (collectively, Defendants), alleging negligence. The trial justice granted the Defendants' motion for summary judgment, concluding that Plaintiff had not raised a genuine issue of material fact and had failed to demonstrate that Defendants owed Plaintiff a duty of care or a duty to warn. The Supreme Court affirmed, holding that Defendants did not owe Plaintiff a duty of care because (1) Plaintiff's injuries occurred on a public sidewalk that was not within Defendants' control or possession; and (2) a property owner who owes no duty of care to an individual also owes no duty to warn those individuals. View "Wyso v. Full Moon Tide, LLC" on Justia Law