Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of one count of child enticement. Defendant subsequently filed a motion for a new trial, arguing that there was insufficient evidence to support a conviction on the count of child enticement. The trial justice denied the motion. Defendant subsequently filed a second motion for a new trial based on a claim of newly discovered evidence, which the trial justice also denied. At the conclusion of the hearing on Defendant's second motion for a new trial, the trial judge adjudged Defendant in contempt of court. The Supreme Court affirmed the judgment of conviction as well as the adjudication of contempt, holding (1) Defendant waived the opportunity to argue the insufficiency of the evidence before the Court; (2) the trial justice did not overlook or misconceive material evidence, nor was he otherwise clearly wrong in denying Defendant's second motion for a new trial; and (3) the trial justice did not err in summarily adjudicating Defendant in contempt. View "State v. Price" on Justia Law

After a jury trial, Defendant was convicted of carrying a firearm in a motor vehicle without a license. Defendant appealed, arguing that the trial justice erred (1) when he denied Defendant's motion to suppress a revolver and bullets that Defendant alleged were illegally seized, and (2) in denying Defendant's motion of acquittal. The Supreme Court affirmed, holding (1) the search that led to the seizure of the contested evidence was constitutionally valid, and therefore, the trial justice did not err in denying Defendant's motion to suppress; and (2) there was sufficient evidence to uphold Defendant's conviction, and therefore, the trial justice did not err when he denied Defendant's motion for a judgment of acquittal. View "State v. Santos" on Justia Law

This case involved a dispute between the R.I. Department of Corrections (DOC) and the certified bargaining unit for correctional officers and other DOC employees (the union). The dispute arose from the DOC's proposal to modify the weapons qualification component of the training program for correctional officers. The union filed a grievance, arguing that the training program could not modified without the approval of a training committee that had been created under the parties' collective bargaining agreement (CBA). An arbitrator ruled in the union's favor. The superior confirmed the arbitration award. The Supreme Court affirmed, holding (1) this dispute was arbitrable; and (2) the arbitration award must stand because the arbitrator's interpretation of the CBA was passably plausible, did not reflect a manifest disregard for the law, and was not irrational. View "State Dep't of Corr. v. R.I. Brotherhood of Corr. Officers" on Justia Law

This litigation stemmed from a dispute over monies allegedly owed to a now-defunct corporation for work performed as part of a construction project that took place in 1990. Plaintiff corporation instituted suit about twenty-two years ago. Seventeen years later, the superior court dismissed the action, finding that Plaintiff could neither maintain the action in its own name nor substitute another entity as Plaintiff. The Supreme Court affirmed, holding that, as a defunct corporation, Plaintiff could no longer maintain this action in its own name, and because the receiver was discharged when Plaintiff was dissolved, the receiver could not maintain the action on its behalf. View "Piccoli & Sons, Inc. v. E & C Constr. Co., Inc." on Justia Law

Defendant was charged with two counts of felony assault. After a jury trial, Defendant was convicted of the lesser-included offense of simple assault and of a serious bodily injury felony assault. Defendant appealed, arguing that the trial justice erred by denying his motion for judgment of acquittal and his motion for a new trial. The Supreme Court affirmed the judgment of conviction, holding (1) there was sufficient evidence to support a conviction of felony assault, and therefore, the trial court did not err in denying Defendant's motion for a new trial; and (2) any analysis of the denial of Defendant's motion for judgment of acquittal was unnecessary. View "State v. Gaffney" on Justia Law

After a jury trial, Defendant was convicted of seven counts of simple assault. At the time of the alleged incidents, Defendant was a captain at the Rhode Island Adult Correctional Institutions (ACI). The charges leveled against Defendant related to his treatment of four ACI inmates. The Supreme Court affirmed the judgment of conviction, holding that the trial justice did not commit reversible error when he (1) denied Defendant's motion to sever his trial from that of his co-defendant; (2) granted the prosecution's motion to preclude the testimony of an inmate; (3) denied Defendant's motion for a new trial; (4) instructed the jury; and (5) allowed the prosecution to introduce certain photographs into evidence that were not disclosed during discovery, as the nondisclosure was inadvertent and did not prejudice Defendant. View "State v. Botas" on Justia Law

Plaintiff was a business agent for a labor organization that represented former employees of the public library. On June 30, the library terminated the employment of thirty-eight union employees. Plaintiff filed a complaint with the Department of Labor and Training (DLT)'s Division of Labor Standards, alleging that the library had failed to pay the employees vacation pay that the employees had accrued at the time of their termination. A hearing officer concluded that the employee's vacation time accrued on July 1 of each fiscal year, and because the employees were not employed on that date, they were not entitled to vacation pay. Plaintiff appealed, The superior court dismissed the complaint for lacking of jurisdiction, ruling that Plaintiff's complaint was untimely filed. The Supreme Court quashed the decision of the superior court and remanded, holding (1) Rule 6 of the Superior Court Rules of Civil Procedure applies to the superior court's review of administrative decisions; and (2) under Rule 6, Plaintiff's complaint would have been timely filed. Remanded. View "McAninch v. State Dep't of Labor and Training " on Justia Law

Plaintiff sustained injuries when he was shot by Defendant, a police officer. Plaintiff filed a civil action against Defendant seeking damages. The jury entered a verdict in Defendant's favor, finding Plaintiff did not prove that Defendant acted unreasonably under the circumstances when he shot and injured Plaintiff. Plaintiff appealed, asserting that he was unfairly prejudiced when the trial justice allowed Defendant to introduce into evidence a redacted police department database report that included Plaintiff's basic biographical information, his mug shot, and a reference to his arrest for possession of a shotgun in 1992. The Supreme Court affirmed, holding that the trial justice did not abuse his discretion in admitting the redacted report. View "Thomas v. Proctor" on Justia Law

This case involved a mediated settlement agreement between two of the heirs of Alfredo and the executrix of his estate, Maria. The superior court ordered Plaintiffs, Lucilio and Patricia, to execute general releases and pay attorney's fees incurred by Maria in seeking to enforce the settlement agreement. Plaintiffs appealed, arguing that the superior court erred in ordering them to execute general releases with terms that were materially different from those contemplated during settlement negotiations, and in assessing attorney's fees. The Supreme Court vacated the judgment of the superior court, holding (1) the trial justice erred in ordering Plaintiffs to execute the general release where the general release's language exceeded the clear and unambiguous terms of the settlement agreement; and (2) the superior court erred in awarding attorney's fees to Defendant pursuant to R.I. Gen. Laws 9-1-45, as the statute's threshold requirement that the party to receive the attorney's fees award be the "prevailing party" had not been met. View "Furtado v. Goncalves" on Justia Law

After Defendant failed to repay a loan Plaintiff made to him in the amount of $8,500, Plaintiff filed a complaint against Defendant alleging breach of contract and breach of an implied-in-fact contract. Plaintiff later amended his complaint to include a claim for failure to repay based on book account. After a jury, the trial justice ordered Defendant to pay damages to Plaintiff in the amount of $8,500. Defendant appealed, contending that the trial justice erred in finding that Plaintiff was a credible witness and in failing to find that the transaction was void because Plaintiff had allegedly advanced the money to Defendant with the knowledge that it would be used for gambling. The Supreme Court affirmed, holding that the Court had no choice but to uphold the lower court's findings because the Court was not provided with a transcript of the trial below and therefore was unable to properly engage in a review of the trial justice's factual findings. View "Vogel v. Catala" on Justia Law