Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Wesley Spratt was found guilty of murder while committing or attempting to commit robbery, first-degree robbery, carrying a pistol without a license, and committing a crime of violence while armed with a firearm. The Supreme Court affirmed the convictions. Spratt subsequently filed a petition for postconviction relief. The superior court eventually denied the petition after a hearing on the merits. The Supreme Court affirmed, holding (1) the hearing justice did not err in finding that Spratt's contention that a courthouse identification of Spratt by a witness was improperly orchestrated by the state was without merit; (2) Spratt did not meet his burden of showing sufficient evidence of the State's alleged coercion of the witness; (3) Spratt did not meet his burden of showing that any discovery violation occurred; (4) the hearing justice correctly rejected Spratt's claim of unlawful sentencing; (5) Spratt's allegations of ineffective assistance of counsel were unavailing; and (6) the hearing justice did not err in finding that the evidence presented at trial was sufficient to convict Spratt. View "Spratt v. State" on Justia Law

Plaintiff, a diesel mechanic, brought suit against Defendant, his former employer, for damages to his tools that allegedly occurred after Defendant fired him. The superior court entered judgment in favor of Plaintiff for $7,360 in damages. Defendant appealed. The Supreme Court affirmed, holding that the trial justice did not err (1) by denying Defendant's motion for judgment as a matter of law, as Plaintiff presented sufficient evidence establishing the damages element of the negligence claim; (2) by permitting the testimony of a witness whose name was absent from the initial witness list, as the witness's appearance at trial could not have created an element of surprise or otherwise prejudiced Defendant; and (3) in calculating the damages. View "Hernandez v. JS Pallet Co." on Justia Law

At issue in this appeal was whether a family court justice erred in finding that loans taken out by Defendant JoAnne Palin to pay for the the college educations of her and Plaintiff Steven Palin's children were not marital debt. JoAnne argued on appeal that the loans at issue should have been considered marital debt by the trial justice because they were incurred during the marriage and were for the benefit of the couple's children. The Supreme Court affirmed, holding that in light of the trial justice's findings that JoAnne's testimony was less than credible, the loans were signed by JoAnne without Steven's consent, the documentary evidence of the loans was never introduced into evidence as to whether the loans were actually for the benefit of either child, and at the time the loans were taken out, the family was in dire financial straits, the trial justice's exclusion of these loans from the marital estate was a sustainable exercise of his discretion to classify and assign marital debts. View "Palin v. Palin" on Justia Law

When Plaintiffs' efforts to act as general contractors on a new home foundered because of faulty work performed by a framing subcontractor, they made a claim on the homeowner's insurance policy issued to them by Defendant, Peerless Insurance Company. After Defendant denied the claim, citing two exclusions in the policy, Plaintiffs filed a declaratory-judgment action against the carrier. A hearing justice determined that the terms of the policy were ambiguous. Consequently, the hearing justice construed the policy against the insurer and entered judgment for the plaintiffs. The Supreme Court affirmed, holding (1) the trial justice did not err when she determined that the policy was ambiguous; and (2) Plaintiffs were entitled to coverage for the repairs that were necessary to bring their home into compliance with the applicable building code. View "Koziol v. Peerless Ins. Co." on Justia Law

After a probation violation hearing, Defendant Santo Jensen was found to have violated the terms and conditions of his probation for allegedly sexually assaulting a six-year-old. Jensen was sentenced to serve the seven-year suspended portion of a ten-year sentence that had previously been imposed pursuant to his conviction on one count of breaking and entering a dwelling. The Supreme Court affirmed the judgment of the superior court, holding that the hearing justice did not act arbitrarily or capriciously in (1) assessing the credibility of the complaining witness or in adjudicating defendant to be a probation violator; (2) crediting the complaining witness's testimony; or (3) weighing the evidence presented at the probation violation hearing to support the conclusion that Defendant had violated his probation. View "State v. Jensen" on Justia Law

Plaintiff, an irrevocable trust, filed a complaint against Defendant, a university graduate student, alleging that he breached his lease agreement by painting over expensive historical wallpaper inside Plaintiff's nineteenth century building and by failing to pay the last month's rent. The superior court trial justice found that Defendant breached the lease by painting portions of the premises but ruled that Plaintiff had failed to prove that the trust had incurred damages that exceeded the amount of unpaid rent. The trial justice then awarded Plaintiff $1,600, plus interest, representing one month of unpaid rent. The Supreme Court vacated the judgment with respect to that portion of the trial justice's decision declining to award damages for the repair of Plaintiff's property and for her failure to award attorney's fees, holding (1) the trial justice erred when she determined damages because she applied the wrong standard; and (2) the clear language of the lease agreement provided contractual authorization for the award of attorneys' fees, and the trial justice abused her discretion in failing to do so. View "Sophie F. Bronowiski Mulligan Irrevocable Trust v. Bridges" on Justia Law

In two civil actions, Plaintiffs in the underlying action alleged that Cheaters, Inc. and Cheaters Holding Corporation negligently and/or recklessly served alcoholic beverages to William Powers, who afterwards drove a vehicle off the premises and collided with other vehicles, resulting in one death and injuries to others. Before the accident, United National Insurance Corporation had issued an insurance policy to Cheaters and the Holding Corporation. Based on the policy's on-premises endorsement and liquor liability exclusion, United National disclaimed any responsibility for the defense and/or indemnification of the Holding Corporation. Plaintiff corporations then filed a complaint seeking a declaratory judgment as to their rights under the terms of the policy. The superior court hearing justice granted United National's motion for summary judgment on the grounds that the on-premises endorsement, which limited coverage to on-premises losses only, applied. The Supreme Court affirmed, holding that coverage was barred by the on-premises endorsement. View "Cheaters, Inc. v. United Nat'l Ins. Co." on Justia Law

The Town of North Providence hired Everett McCain and appointed him as a lineman in the communications division of the fire department. McCain subsequently sustained injuries during the performance of his duties. Accordingly, the Town rendered injured-on-duty (IOD) payments to McCain pursuant to R.I. Gen. Laws 45-19-1. Later, the Town ceased making payments to McCain on the ground that McCain was not a "sworn firefighter" and, for that reason, was ineligible to collect IOD payments. McCain filed a petition for a writ of mandamus, asserting his right to IOD benefits. The superior court denied the writ but granted declaratory relief in favor of McCain, concluding that McCain was qualified as a "firefighter" eligible to receive benefits under section 45-19-1. The Supreme Court affirmed, holding that, based on the clear and unambiguous language set forth in section 45-19-1(c), McCain met the definition of "firefighter" at the time of his injury for purposes of collecting IOD benefits under that statute. View "McCain v. Town of N. Providence" on Justia Law

Plaintiff James Casale was employed by Defendant City of Cranston when he was injured. During his incapacity, Plaintiff received injured-on-duty (IOD) benefits from the City. In accordance with its policy with Plaintiff, Plaintiff's insurer, Amica Mutual Insurance Company, tendered $100,000 in uninsured motorist benefits to Plaintiff minus the amount that the City paid to Plaintiff for IOD benefits. Plaintiff subsequently initiated this declaratory judgment action seeking a judicial determination that R.I. Gen. Laws 45-19-1.1, which requires that an employer be reimbursed out of the proceeds received from the third party, was inapplicable to his case and that the City was not entitled to reimbursement from uninsured motorist benefits Plaintiff recovered under the policy. The trial justice concluded that the City was not entitled to reimbursement. The Supreme Court affirmed, holding (1) the trial justice correctly held that Defendant was not entitled to reimbursement for the IOD payments paid to Plaintiff; and (2) because Plaintiff did not collect any money from the tortfeasor, section 45-19-1.1 was inapplicable to this case. View "Casale v. City of Cranston" on Justia Law

Applicant Jerry Steele entered a plea of nolo contedere to assault with a dangerous weapon. Applicant subsequently filed a pro se motion for postconviction relief, alleging, inter alia, that he was forced against his will to enter a guilty plea. After the superior court appointed an attorney for applicant, the court denied the motion. Applicant appealed, contending that his court-appointed attorney provided ineffective assistance of counsel during the postconviction-relief hearing. The Supreme Court affirmed, holding that Applicant's contention concerning alleged ineffective assistance of counsel at the postconviction-relief hearing was not property before it, as Applicant's argument on appeal was not presented to the superior court. View "State v. Steele" on Justia Law