Justia Rhode Island Supreme Court Opinion Summaries

Plaintiff filed suit against Defendant, one of his former law partners, after that law practice was dissolved. Plaintiff's complaint alleged intentional interference with prospective contractual relations, defamation, and corporate opportunity doctrine. The trial justice entered judgment against Plaintiff , finding that the evidence was insufficient as a matter of law to prove damages arising from the alleged tortious conduct of Defendant. The court subsequently denied Plaintiff's motion for a new trial. The Supreme Court affirmed, holding that the trial justice did not err (1) in concluding that damages for loss of reputation in a claim for tortious interference with a contract must be properly quantified; (2) in finding that the term "smoking gun" was not slanderous per se; and (3) in failing to submit Plaintiff's claim of breach of fiduciary duty to the jury. View "Bossian v. Anderson" on Justia Law

Defendant's employer had insurance through American States Insurance Policy (ASIC). After Defendant was involved in a car accident, Defendant sent ASIC written notice of a potential claim under ASIC's uninsured/underinsured (UM/UIM) coverage. ASIC did not formally deny the claim but, rather, responded with a declaratory-judgment action, asserting that because Defendant had failed to undertake legal action or to make a written demand for arbitration against ASIC within three years from the date of the accident, her UIM claim against ASIC was time-barred. The U.S. district court entered judgment on the pleadings in favor of ASIC, determining that the three-year limitations period set forth in the policy did not violate public policy. On appeal, the court of appeals certified a question of law to the Rhode Island Supreme Court, which answered by holding that Rhode Island would not enforce the contractual limitations clause in this case because it began to run on the date of the accident rather than the date the insurance contract was breached and was shorter than the statutory limitations period. View "Am. States Ins. Co. v. LaFlam" on Justia Law

At issue in this case was two properties consisting of neighboring condominiums. In 2005, Defendants placed barriers in Plaintiffs' claimed right of way, which impeded vehicle access and foot traffic. After Defendants refused to remove the barrier, Plaintiffs sued Defendants, alleging that, according to a condominium declaration, Plaintiffs had an express easement over the right of way, or, in the alternative, they had an implied or prescriptive easement over the right of way. After a trial, the trial justice ruled in favor of Defendants. The Supreme Court (1) vacated the judgment of the superior court with respect to its determination that Defendants did not have a claim of an implied easement by reservation over the right of way, as the trial justice did not make any findings or legal conclusions with respect to whether Plaintiffs had an implied easement by grant over the claimed right of way; and (2) affirmed in all other respects. Remanded. View "Wellington Condo. Ass'n v. Wellington Cove Condo. Ass'n" on Justia Law

After a bench trial, Defendant was convicted of criminal counts, including larceny, assault with a dangerous weapon, and violation of a protective order. Defendant appealed, arguing, among other things, that the State failed to comply with the Interstate Agreement on Detainers Act (IADA), and therefore, the trial court erred when it did not dismiss the charges against him. The Supreme Court affirmed the convictions, holding (1) the trial court did not err in denying Defendant's motion to dismiss, as Defendant forfeited his IADA argument for failing to raise it before the deadline expired; and (2) Defendant's convictions for both larceny and assault with a dangerous weapon did not violate the Double Jeopardy Clauses of the state and federal constitutions. View "State v. Oliver " on Justia Law

Defendant pled nolo contendere to assault with a dangerous weapon. The trial justice sentenced Defendant to twenty years incarceration, with ten years to serve and ten years suspended with probation. One year after Defendant unsuccessfully moved for a sentence reduction under R.I. R. Crim. P. 35, Defendant filed a motion requesting the trial justice assign for a hearing the previously filed Rule 35 motion. After a hearing, the trial justice granted the motion and amended Defendant's sentence to twenty years, nine years to serve and eleven years suspended with probation. The Supreme Court quashed the superior court's judgment modifying Defendant's term to serve, holding that Defendant's motion to reduce sentence/assign pursuant to Rule 35 was not properly before the trial court because, notwithstanding the language contained within the text of that motion, the filing was an untimely filed new motion, and therefore, the trial justice erred in granting the motion. View "State v. Keenan" on Justia Law

After a jury trial, Defendant was convicted of first degree sexual assault. The Supreme Court affirmed the conviction, holding that the trial court did not err in (1) declining to dismiss the indictment based upon a partially inaudible and incomplete grand jury record, as an unintentional failure to record or reproduce the grand jury proceedings does not affect the validity of the prosecution; (2) denying Defendant's motion to pass the case based upon Sup. Ct. R. Crim. P. 16 violations by the state, where a violation of Rule 16 occurred in this case, but the nondisclosures were not deliberate on the part of the prosecutor; and (3) admitting the testimony of an expert in the field of sexual abuse, as the testimony did not constitute impermissible vouching or bolstering of other fact witnesses. View "State v. Huffman" on Justia Law

Defendant was indicted for several sex-related crimes. Defendant opted to exercise his constitutional right to represent himself. After the jury was sworn, Defendant expressed his desire to absent himself from the trial in the event a plea agreement was not reached. The trial continued in Defendant's absence. The jury subsequently found Defendant guilty of three counts of first-degree child molestation sexual assault and two counts of first-degree sexual assault. Defendant appealed, contending, among other things, that the trial justice was constitutionally required to appoint counsel to represent him when he absented himself from trial. The Supreme Court affirmed, holding (1) Defendant validly waived his right to counsel; (2) the trial justice did not abuse his discretion in denying Defendant's post-waiver request for counsel; (3) the trial justice was not constitutionally required to appoint counsel to represent Defendant after he chose to proceed pro se and then absented himself from trial; and (4) Sup. Ct. R. Crim. P. 43 did not present any bar to Defendant's trial continuing, even after he elected not to be present. View "State v. Eddy" on Justia Law

Plaintiff was a condominium unit owner in a condominium community comprised of three sub-condominium residential areas. Plaintiff filed an application for approval to demolish his existing unit and rebuild a larger unit. After America Condominium Association asserted that Plaintiff did not own the land on which he sought to expand, Plaintiff filed a complaint against America seeking a declaratory judgment that he had sufficient interest to file an application regarding the expansion of his unit onto adjoining land. Plaintiff then brought an action against the larger condominium association and the other sub-condominium associations in the community, essentially parroting the allegations set forth in the America action. In both actions, the hearing justice concluded that Plaintiff had standing to file his application for the expansion of his unit but that Plaintiff's proposed expansion required the unanimous consent of the other 153 unit owners. The Supreme Court primarily affirmed, holding (1) Plaintiff had standing to file the application for expansion; but (2) pursuant to the Condominium Act, the unanimous consent of all of the unit owners must be obtained before Plaintiff could carry out his unit expansion. View "Sisto v. Am. Condo. Ass'n" on Justia Law

Wife filed for a divorce from Husband. Thereafter, Husband unsuccessfully filed a motion to dismiss the complaint, contending that the family court did not have jurisdiction because Wife had not been a resident of the State for one year prior to the filing of the complaint. In the meantime, Wife filed an emergency motion for seeking an order restraining Husband from proceeding with a divorce action in any other jurisdiction, which the trial justice granted. After a trial, the trial justice sanctioned Husband for violation of a discovery order, distributed the martial property, found Wife was entitled to rehabilitative alimony, ordered that Husband should pay Wife counsel fees, and found that Husband was in contempt of court because he violated the prior order restraining him from proceeding with a divorce in another jurisdiction. The Supreme Court affirmed, holding that the trial justice did not err (1) in denying Husband's motion to dismiss for lack of subject matter jurisdiction, as Wife residency in the State met the subject matter jurisdiction requirements of the pertinent statute; (2) in awarding Wife rehabilitative alimony; (3) with respect to the award of counsel fees; and (4) in his adjudication of Husband as being in contempt of court. View "Meyer v. Meyer" on Justia Law

Wife filed a complaint for an absolute divorce, and Husband filed a counterclaim. As grounds for divorce, both parties cited irreconcilable differences. The proceedings in the family court spanned almost five years. The family court eventually granted Wife's complaint. At issue on appeal was the court's distribution of the stock of Microfibres, Inc. (Microfibres), of which Husband was the president and CEO, and Microfibres Partnership Limited (MPL). The Supreme Court (1) affirmed the portion of the family court's decision addressing the portion of MPL that was marital property and the trial justice's grant of partial summary judgment holding that the stock of Microfibres was marital property; and (2) vacated the portion of the decision addressing the equitable distribution of the marital estate, holding that the trial justice erred when he declined to value his assignments of Microfibres and MPL. Remanded with direction to value Microfibres and MPL as of the date of trial and to distribute the marital estate in accordance with R.I. Gen. Laws 15-5-16.1. View "McCulloch v. McCulloch" on Justia Law