Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first-degree murder and three firearms charges. The Supreme Court affirmed Defendant's convictions on all counts. Defendant subsequently filed an application for postconviction relief, alleging ineffective assistance of counsel. The superior court denied Defendant's application. The Supreme Court affirmed, holding that the trial court did not err in concluding (1) trial counsel did not have an actual conflict of interest during Defendant's representation that adversely affected the lawyers' performance; and (2) Defendant's attorneys did not render ineffective assistance in choosing not to pursue a motion to suppress evidence or to mount a third-party perpetrator defense. View "Rivera v. State" on Justia Law

Defendant was a nonprofit conservation corporation that owned beachfront property. Plaintiff filed a complaint seeking the superior court's recognition of its right to traverse Defendant's land to get access to its own property. Plaintiff then amended its complaint to add a claim for easement by prescription. The superior court recognized a prescriptive easement over Defendant's property. The Supreme Court vacated the judgment of the superior court, holding (1) Plaintiff's first complaint sufficiently pleaded a claim for an easement by prescription; but (2) Plaintiff did not establish by clear and convincing evidence that a prescriptive easement existed over Defendants' property. Remanded to permit the parties to supplement the existing record. View "R.I. Mobile Sportfishermen, Inc. v. Nope's Island Conservation Ass'n" on Justia Law

After a jury trial, Defendant was sentenced to life imprisonment for the first-degree murder of his mother. Defendant subsequently filed an application for postconviction relief. The superior court appointed counsel to represent Defendant in connection with his application, but counsel determined that the issues raised in the application were frivolous and without merit and moved to withdraw as attorney of record. After a hearing and a finding that Defendant's arguments were meritless, the hearing justice granted the motion. The hearing justice then denied and dismissed Defendant's application. The Supreme Court affirmed, holding that the hearing justice did not err in (1) granting counsel's motion to withdraw, as all of the procedural requirements of Shatney v. State were followed; and (2) denying Defendant's application after giving Defendant ample opportunity to respond to the proposed dismissal of his application. View "Perez v. State" on Justia Law

Pearl Archambault died while in the care of Haven Health Center of Greenville (Haven Health) after a nurse mistakenly administered a lethal overdose of morphine. The administratrix of her estate, Plaintiff, filed a medical malpractice action against Haven Health. Health Haven subsequently filed for Chapter 11 bankruptcy. Thereafter, Plaintiff amended her complaint to add Columbia Casualty Company, the professional liability insurer of Health Haven, as a defendant and asserted two counts against Columbia directly based on R.I. Gen. Laws 27-7-2.4, which permits an injured party to proceed against an insurer when the insured has filed for bankruptcy. The superior court entered default judgment against Haven Health. The court then granted summary judgment in favor of Columbia. The Supreme Court reversed and remanded with instructions to enter judgment against Columbia, holding that the superior court erred in interpreting Rhode Island law and that the insurance contract between Columbia and Health Haven should be construed in Plaintiff's favor. View "Peloquin v. Haven Health Ctr. of Greenville, LLC" on Justia Law

Dean Pepper, the owner and sole shareholder of D.F. Pepper Construction (DFP) was driving one of his trucks home in the early winter morning. An icy road caused the truck to slide into Pepper's house and crash through the foundation and west wall. The house was later condemned and demolished as a result of the damage. The house was insured by Nationwide Casualty Insurance Company. Nationwide paid the loss. As subrogee of Pepper, Nationwide then sued DFP, the registered owner of the truck, alleging vicarious liability for the negligence of its employee, Pepper. The superior court issued judgment in favor of Nationwide, finding that Pepper had been negligent and that the antisubrogation rule did not apply in this case. The Supreme Court affirmed, holding that the trial court did not err in its judgment. View "Nationwide Prop. & Cas. Ins. Co. v. D.F. Pepper Constr., Inc." on Justia Law

DWS Properties (DWS) owned rental property. The sole member of DWS was Dustin Shore. After a pipe burst at the property causing substantial damage, Shore executed contracts with Performance Adjusting Public Insurance Adjusters (Performance) and Multi-State Restoration (Multi-State), in which Performance agreed to provide public adjusting service relative to the loss, and Multi-State agreed to perform emergency clean-up work at the property. Performance and Multi-State (Plaintiffs) were never paid for the services they provided, and after Shore filed for personal bankruptcy, Shore's debts to Plaintiffs were discharged. Plaintiffs subsequently filed suit against DWS, seeking damages for book account, breach of contract, quasi-contract, and unjust enrichment. DWS filed a motion to dismiss, which the hearing justice converted into a motion for summary judgment and granted, reasoning that Shore had signed the contracts in an individual capacity without making any reference to DWS. The Supreme Court vacated the judgment of the superior court and remanded, holding (1) summary judgment was inappropriate on Plaintiffs' contract claims; and (2) the fact that DWS was not explicitly named on the contracts did not entitle it to judgment as a matter of law on Plaintiffs' equitable claims. View "Multi-State Restoration, Inc. v. DWS Props., LLC" on Justia Law

Defendant entered pleas of nolo contendere to three counts of second-degree child molestation, and the hearing justice accepted Defendant's plea. Five months later, Defendant filed an application for postconviction relief, claiming that his conviction should be vacated because his plea was involuntary and because he had been denied his right to the effective assistance of counsel. The superior court dismissed Defendant's application. The Supreme Court affirmed, holding (1) Defendant voluntarily pleaded to the charges; (2) Defendant's attorney did not render ineffective assistance in pressuring him to plead to the charges or in failing to advise Defendant to inform the court that he had ingested prescription medication during the plea hearing; and (3) the hearing justice did not err in failing to draw an adverse inference against the state based on its failure to call upon Defendant's plea attorney to testify at the postconviction-relief hearing. View "Jolly v. Wall" on Justia Law

Dr. James Gallo treated Plaintiff in 2003 and 2004. Thereafter, Plaintiff filed a complaint against Gallo and West Bay Psychiatry Associations, including claims for slander for remarks uttered in two separate proceedings. The first alleged slander occurred when Gallo's deposition was taken in connection with Plaintiff's case before the Workers' Compensation Court (WCC). The second alleged slander occurred when Gallo testified before the Rhode Island Department of Education (RIDE) regarding Plaintiff's alleged wrongful termination from her teaching position. The superior court entered summary judgment for Defendants on Plaintiff's slander claims. The Supreme Court affirmed, holding that the motion justice did not err in finding (1) Plaintiff's claim for slander based on Gallo's WCC deposition testimony was time-barred; and (2) Plaintiff's claim for slander based on Gallo's RIDE testimony was immunized from defamation claims by the testimonial privilege because it qualified as having occurred in a judicial proceeding. View "Francis v. Gallo" on Justia Law

A motor vehicle collision involving Plaintiff and Defendant occurred when Plaintiff was riding his motorcycle and Defendant was driving a car belonging to his girlfriend. Plaintiff filed a complaint against Defendant and his girlfriend, alleging that Defendant had been negligently operating the car at the time of the collision. Defendants filed a motion for summary judgment, contending that the incident was in actuality a rear-end collision caused by Plaintiff. The superior court granted Defendants' motion, concluding that Plaintiff had struck the car from the rear. The Supreme Court reversed, holding that there was sufficient conflicting evidence on the issue of negligence for this case to be submitted to a fact-finder. View "DeMaio v. Ciccone" on Justia Law

Plaintiff was a Massachusetts corporation when it entered into a contract with Defendants. The contract was to be performed entirely in Rhode Island. Defendants subsequently commenced a civil action against Plaintiff. At the time, Plaintiff had a certificate of authority from the secretary of state, but after Plaintiff filed this action, the corporation's certificate of authority was revoked. The superior court granted summary judgment in favor of Defendants, determining that Plaintiff did not have a certificate of authority to transact business in Rhode Island, and therefore, it lacked the capacity to sue in the state. The Supreme Court reversed, holding that a certificate was not required in this instance, but Plaintiff must obtain a certificate before proceeding to final judgment. View "Custom Metals Sys., Ltd. v. Tocci Building Corp." on Justia Law