Justia Rhode Island Supreme Court Opinion Summaries

Plaintiff was an inmate serving a life sentence incarcerated at the Adult Correction Institutions (ACI). Plaintiff filed an amended complaint naming as defendants employees of the ACI and Department of Corrections (DOC), alleging that Defendants violated his right to privacy by monitoring him via video camera while he was in his prison cell and that Defendants regularly harassed him. The trial justice dismissed the complaint. The Supreme Court affirmed. Meanwhile, Plaintiff filed another complaint against thirteen employees of the DOC. Along with the complaint, Plaintiff filed a motion to proceed in forma pauperis. The trial court denied Plaintiff's motion and entered an administrative order restricting Plaintiff from filing any further pro se actions in superior court. The Supreme Court vacated the orders restricting Plaintiff from filing any pro se actions, holding that the order did not comport with Supreme Court precedent and impermissibly infringed upon Plaintiff's right of access to the courts. View "Laurence v. R.I. Dep't of Corr." on Justia Law

Buyers purchased real estate and retained Attorneys in connection with their purchase. Buyers sued Attorneys, alleging that, due to Attorneys' negligence, they overpaid Seller by more than $1,700,000. Attorneys filed a motion for leave to file a third-party complaint naming Agents as third-party defendants, alleging that Agents had a fiduciary duty to both Seller and Buyers and that if Buyers were entitled to recover for their alleged damages, then Agents would be liable for all or part of Buyers' claims against Attorneys. The superior court granted the motion. A motion justice subsequently granted Agents' motions to dismiss the third-party complaint, finding that the third-party complaint failed to plead a duty owed by Agents to either Buyers or Attorneys. The Supreme Court disagreed and vacated the superior court's subsequent denial of Attorneys' second motion for leave to file a third-party complaint, holding that Attorneys' second proposed third-party complaint fell within the scope of R.I. R. Civ. P. 14, which governs impleader. View "Wampanoag Group, LLC v. Iacoi" on Justia Law

After a trial at which he represented himself, Defendant was convicted of kidnapping, domestic felony assaults, intimidation of a witness, and violation of a no-contact order. The Supreme Court affirmed the convictions. Defendant subsequently filed several motions, which the superior court treated as a subsequent application for postconviction relief and then denied. In the motions, Defendant argued, inter alia, that the prosecutor erred in failing to produce certain victim-impact statements in response to his discovery requests. The Supreme Court affirmed, holding (1) even if the claims underlying this postconviction relief application were not barred by res judicata, they were meritless; (2) even if the State had disclosed the victim-impact statements to Defendant before trial, Defendant failed to demonstrate that the result of his trial would have been different, and therefore, Defendant's claim that the State violated Brady v. Maryland failed; (3) Defendant was not prejudiced by the State's failure to disclose the victim-impact statements under R.I. R. Evid. 16; and (4) Defendant was not entitled to postconviction relief based on newly discovered evidence. View "State v. Thornton" on Justia Law

After a jury trial, Defendant was convicted of simple domestic assault. The Supreme Court affirmed the judgment of conviction, holding that the trial justice (1) did not err in giving a jury instruction with respect to intent; (2) did not err in limiting Defendant's constitutional right to cross-examination of the complainant; (3) did not err in allowing a witness to express his opinion that Defendant was the aggressor because even if the testimony consisted of impermissible vouching, the admission of the testimony did not constitute prejudicial error; and (4) Defendant failed to establish any prejudice arising from the complainant's email having been read into the record rather than having been marked as an exhibit or otherwise provided to Defendant. View "State v. Kausel" on Justia Law

While on probation, Defendant fled from two police officers. After Defendant was arrested, a firearm was discovered on the floor of his car. A trial justice later found Defendant to be a violator of the terms and conditions of his probation. In addition to the probation-violation proceeding, the State charged Defendant with recklessly operating a motor vehicle, carrying a revolver without a license, and possession of a firearm after having been convicted of a crime of violence. During the course of the violation hearing, the State requested, in a motion in limine, that the trial justice interpret the Firearms Act in such a manner that a weapon need not be capable of expelling a projectile to fit within the definitions of "firearm" or "pistol." The trial justice denied the motion. The Supreme Court affirmed, holding (1) the trial justice did not err in finding that Defendant violated the terms of his probation; and (2) the trial justice correctly denied the State's motion in limine. View "State v. Hazard" on Justia Law

After a jury trial, Defendant was convicted of first degree child abuse for inflicting serious bodily injury on his infant son. Defendant was sentenced to twenty years incarceration. The Supreme Court affirmed the conviction, holding (1) the trial justice correctly denied Defendant's challenge to the constitutionality of the child abuse statute; (2) the trial justice did not err when he admitted a statement that Defendant wrote at the police station because Defendant knowingly and voluntarily waived his Miranda rights before providing the statement; and (3) the trial justice did not err in denying Defendant's motion for a judgment of acquittal and his motion for a new trial. View "State v. Allen" on Justia Law

The Providence School Board (Board) provided health insurance to active employees and retirees. In 2006, the Providence Teachers Union (Union) filed a grievance protesting a difference in the increase of premium costs for retirees compared with a more modest increase in premium costs for active employees. The Union argued that the Board's action violated three provisions of the collective bargaining agreement (CBA) between the board and the union. An arbitrator ruled in the Union's favor, concluding that the Board violated the CBA by failing to include retirees and active employees in a single group when it calculated the healthcare premium rates. The trial justice vacated the arbitration award, concluding (1) the Union did not have standing to pursue a grievance on behalf of retirees, and (2) the issue of the calculation of the group premium rate was not arbitrable. The Supreme Court affirmed, holding (1) pursuant to Arena v. City of Providence and City of Newport v. Local 1080, the Union could not pursue this grievance on behalf of the retirees; and (2) because the Union had no standing to pursue this particular grievance, the grievance was not arbitrable. View "Providence Sch. Bd. v. Providence Teachers Union, Local 958" on Justia Law

Plaintiff filed this negligence action against Defendant, a medical doctor, seeking damages for injuries she sustained after she fell on an entrance ramp to Defendant's podiatric officers during a winter storm. The superior court granted summary judgment for Defendant, concluding (1) there was no dispute that the storm on the day of Plaintiff's fall included snow; (2) Defendant was justified to wait until the storm ended before taking action to treat his office entrance; and (3) Defendant did not owe Plaintiff or other invitees a heightened duty of care. The Supreme Court vacated the lower court's judgment and remanded, holding (1) because the parties disagreed as to the extent of the storm on the day of Plaintiff's fall, additional factual findings were required to determine whether Defendant was under a duty to treat his entranceway before the storm had ended, and thus, the grant of summary judgment was improper; and (2) Defendant did not owe Plaintiff a heightened duty of care. View "Sullo v. Greenberg" on Justia Law

After a jury trial, Defendant was convicted of one count of possession of marijuana and two counts of possession of cocaine with the intent to deliver while armed with or having available a firearm. Defendant appealed, arguing, among other things, that the trial justice erred in permitting the State to impeach his credibility with an allegation of previous criminal conduct and with information that was false and prejudicial. The Supreme Court vacated the judgment of conviction, holding (1) the trial court's questions concerning the nature of the offense with which Defendant was previously charged were improper and inappropriate for impeachment purposes because not only did these questions place factually incorrect information before the jury, but they impermissibly introduced false evidence of Defendant's previous criminal conduct; and (2) the error was not harmless. View "State v. Price" on Justia Law

After a jury trial, Defendant was convicted of first-degree child molestation. Defendant appealed, contending (1) the trial justice erred in denying his motion to suppress a statement he made to the police as the fruit of an unlawful arrest, and (2) the trial justice erred in admitting the statement without first redacting certain portions. The Supreme Court affirmed, holding (1) because Defendant was validly arrested, and because the trial justice did not err in concluding that Defendant knowingly, voluntarily, and intelligently waived his Miranda rights, the court properly denied Defendant's suppression motion; and (2) the trial justice did not err in refusing to redact Defendant's statement to police. View "State v. Morin" on Justia Law