Justia Rhode Island Supreme Court Opinion Summaries

Plaintiff was the mother of two boys. After it was established that the boys were Defendant's children, Defendant moved for visitation, which the family court granted. Defendant was subsequently charged with second-degree child abuse, and the family court awarded sole custody to Plaintiff. Defendant was convicted of second-degree child abuse, but the charges were dismissed on appeal. Thereafter, Defendant unsuccessfully filed a motion for sole custody, arguing that the vacating of his conviction and the dismissal of the second-degree child abuse charge were changed circumstances sufficient to modify the existing custody decree. The Supreme Court affirmed, holding that, in light of Defendant's failure to complete required domestic-violence counseling and drug testing, the family court did not abuse its discretion in denying Defendant's motion to modify custody. View "Catley v. Sampson" on Justia Law

Plaintiff received a wound from a dog bite from a pit bull. Plaintiff filed suit against Defendant, the owner of the building where the dog bite occurred. The superior court granted summary judgment in favor of Defendant, finding that the dog bite at issue occurred within the enclosure of the owner or keeper of the dog. On appeal, Plaintiff argued that a genuine issue of material fact existed as to whether the second-floor apartment where the dog bite occurred was a separate enclosure for purposes of R.I. Gen. Laws 4-13-16. The Supreme Court vacated the judgment of the superior court, holding (1) absent an inquiry into whether the second-floor apartment was kept locked and whether Defendant was excluded from the premises, it was impossible to determine whether the second-floor apartment was a separate enclosure within Defendant's house; and (2) there was a disputed issue of material fact was to whether Defendant knew of or permitted the dog's presence on his premises. View "Carreiro v. Tobin" on Justia Law

The underlying litigation arose from a real estate dispute between Plaintiff and several neighbors of Plaintiff (collectively, Codefendants). Codefendants retained attorneys (Attorney Defendants) to represent them in the property dispute. Attorney Defendants filed a notice of intent on behalf of Codefendants asserting Codefendants' right to their own property. Plaintiff filed a complaint against Defendants and later amended his complaint setting forth claims against Attorney Defendants for slander and title and intentional interference with prospective advantage. The superior court granted summary judgment in favor of Attorney Defendants. The Supreme Court affirmed, holding (1) Plaintiff failed to establish an essential element of his claim of slander of title; and (2) the notice of intent could not be said to constitute an improper act of interference, and therefore, Attorney Defendants were entitled to summary judgment with respect to the intentional interference claim. View "Beauregard v. Gouin" on Justia Law

Plaintiff was injured in a motor-vehicle collision with an underinsured driver (Tortfeasor). Tortfeasor was insured by Progressive Insurance Company (Progressive). Progressive paid Plaintiff its policy limits of $25,000. Plaintiff then sought recovery for personal injuries pursuant to the uninsured/underinsured motorist provisions (UM/UIM coverage) of her policy with Encompass Insurance Company (Encompass). Arbitrators issued a total award of $172,750. Plaintiff sought confirmation of the arbitration award. Encompass objected, arguing that Plaintiff's UM/UIM policy provided $100,000 maximum coverage, that Encompass had paid the policy limits in accordance with the insurance contract, and that, under Rhode Island law, Plaintiff was not entitled to recover from Encompass in excess of her policy limits. The trial justice vacated the portion of the award in excess of the $100,000 policy limit and confirmed the remainder of the arbitration award. The Supreme Court vacated the order of the superior court and directed that the arbitration award be reinstated in its entirety, holding that the superior court was incorrect in its interpretation of the law, and no grounds for modification or vacation of the award existed. View "Wheeler v. Encompass Ins. Co." on Justia Law

Fifteen-year-old Jennifer Rivera was an eyewitness to the murder of Hector Feliciano and was under subpoena to testify in a murder trial. Before the trial, Jennifer was shot several times at close range in order to prevent her from testifying against Defendant, who was charged with and awaiting trial on the Feliciano murder. During the ensuing police investigation, three individuals, including Defendant, were found to have planned and participated in Jennifer's murder. Defendant was subsequently convicted of first-degree murder, conspiracy, obstruction of justice, and numerous firearms counts. The Supreme Court affirmed, holding (1) the trial justice did not abuse his discretion in admitting various items of evidence, including evidence that Defendant committed the Feliciano murder; (2) the trial justice did not err in his instructions to the jury on evaluating witness credibility; (3) the trial justice properly did rejected Defendant's Batson challenge to the State's use of a peremptory challenge; (4) the State did not engage in improper vouching; and (5) the trial justice did not err in denying Defendant's motion for a new trial. View "State v. Pona" on Justia Law

After a jury trial, Defendant was convicted of simple domestic assault. Defendant appealed, contending, inter alia, that the trial justice erred when she allowed a patrolman to testify about Defendant's admission that he owned handcuffs. Defendant alleged (1) the statement was given while he was in police custody and before the police read him his Miranda rights; and (2) the police obtained the admission during an illegal search and seizure. The Supreme Court affirmed, holding (1) Defendant's freedom of movement was not restricted to the degree associated with formal arrest, and therefore, Defendant was not in police custody when he made his statement; (2) because Defendant's answer about handcuffs was not prompted by illegally seized evidence, nor was the answer induced by illegally seized evidence, the trial justice did not violate Defendant's constitutional rights by allowing the patrolman to testify regarding Defendant's admission that he owned handcuffs; and (3) the trial justice did not err in denying Defendant's motion for a new trial. View "State v. Harrison" on Justia Law

Before Decedent's death, the Department of Human Services (DHS) expended $94,162 in medical assistance payments on Decedent's behalf. Neither administratrixes of Decedent's estate notified DHS that Decedent's estate had commenced. More than three years after Decedent's death, DHS learned Decedent's estate had been opened and filed a claim out of time with the probate court, seeking reimbursement for the medical assistance payments it had paid on Decedent's behalf prior to her death. The probate court entered an order allowing the claim. The estate appealed, arguing that DHS's claim was time barred. The superior court concluded that DHS was not precluded under the statute of limitations from filing its claims for medical assistance payments and entered summary judgment in DHS's favor. The Supreme Court affirmed, holding that the statute of limitations was not triggered until the date DHS received notice that the state had been opened, and therefore, its claim was not time-barred. View "In re Estate of Manchester" on Justia Law

Plaintiffs, Nelson and Elaine Cruz, filed a complaint against the car dealership where Nelson purchased his vehicle (Ricky Smith), alleging that while Nelson was cleaning the inside of his minivan, both front airbags unexpectedly deployed, injuring him. Plaintiffs' complaint alleged negligence, strict products liability, negligent misrepresentation, and res ipsa loquitur. In addition, Elaine sought damages for loss of consortium. The trial justice granted Ricky Smith's motion for summary judgment on all counts. The Supreme Court affirmed, holding that the hearing justice properly granted summary judgment in Ricky Smith's favor on Nelson's claims of negligence and misrepresentation, and consequently, Elaine was barred from recovering damages for loss of consortium. View "Cruz v. DaimlerChrysler Motors Corp." on Justia Law

After a jury trial, Defendant was convicted of first degree child abuse for inflicting serious bodily injury on his infant daughter. Defendant appealed, asserting that his right to confrontation under the federal and state constitutions was violated when the trial justice allowed a pediatrician to testify regarding out-of-court statements made by a colleague of hers - an ophthalmologist who performed a retinal exam on the injured infant. The Supreme Court affirmed, holding (1) Defendant failed adequately to raise his constitutional argument at trial; and (2) the narrow exception to the "raise or waive" rule did not apply in this case. View "State v. Moten" on Justia Law

Plaintiff underwent open-heart surgery at Hospital in January 2004. Dr. Singh performed the surgery, and Dr. Schwartz was the echocardiologist assisting with the surgery. Plaintiff was required to undergo a second open-heart surgery in August 2004 because of an errant suture stitched by Dr. Singh during Plaintiff's January surgery. While in recovery from his second surgery, Plaintiff suffered a cardiac arrest. Plaintiff brought a medical malpractice action against Hospital, Dr. Singh, and Dr. Schwartz. Plaintiff subsequently settled his claims against Hospital and Dr. Singh. Plaintiff proceeded to trial on his claims against Dr. Schwartz, and the trial court entered judgment in favor of Plaintiff. The Supreme Court affirmed, holding that the trial justice did not commit reversible error in (1) refusing to instruct the jury on intervening and superseding cause; (2) admitting certain testimony pertaining to Plaintiff's cardiac arrest following surgery in August; (3) denying Defendant's request for a remittutur and motion to vacate the damage award; and (4) instructing the jury on insurance. Additionally, the Court held that R.I. Gen. Laws 9-21-10(b), which mandates prejudgment interest at a rate of twelve percent in certain cases, is constitutional. View "Oden v. Schwartz" on Justia Law