Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the decree of the family court terminating Mother's parental rights with respect to her daughter (Child), holding that the trial justice did not err in finding by clear and convincing evidence that the Department of Children, Youth, and Families (DCYF) made reasonable efforts to achieve reunification between Mother and Child.DCYF filed a petition to terminate Mother's parental rights on the grounds that she and Father were unfit to parent Child under R.I. Gen. Laws 15-7-7(a)(2)(i) and (a)(3). After a trial, the trial justice granted DCYF petition to terminate Mother's parental rights, determining that DCYF met its burden of proving by clear and convincing evidence that it employed reasonable efforts to achieve reunification. The Supreme Court affirmed, holding that the trial justice did not clearly error or overlook or misconceive material evidence in determining that DCYF made reasonable efforts to achieve reunification. View "In re R.M." on Justia Law

The Supreme Court quashed the decision of the superior court granting Defendant's motion to compel production of a complete, unreacted copy of a settlement agreement between Plaintiffs and the former codefendants who settled Plaintiffs' claims, holding that the trial justice abused her discretion in granting Defendant's motion.In granting Defendant's motion to compel production, the trial justice concluded that the amount paid in accordance with the settlement agreement was not discoverable "pursuant to Rhode Island and federal law." When Plaintiffs failed to comply with the order the superior court granted Defendant's motion to dismiss. The Supreme Court quashed the decision below and remanded the case, holding that the trial justice abused her discretion in granting Defendant's motion to compel production of a complete, unreacted copy of the settlement agreement. View "Noonan v. Sambandam" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of two counts of second-degree sexual assault, holding that the trial justice did not err in denying Defendant's motion to pass the case or his motion for a new trial.Defendant was convicted after a trial. The trial justice denied Defendant's motion for a new trial and sentenced him to eight years of imprisonment for each count, with one year to serve and the remaining time suspended. On appeal, Defendant argued, among other things, that the trial justice abused his discretion in denying Defendant's motion to pass the case due to the prosecutor's allegedly improper comments during closing arguments. The Supreme Judicial Court affirmed, holding (1) the trial justice did not abuse his discretion in denying Defendant's motion to pass the case; and (2) the trial justice did not erroneously admit evidence unduly prejudicial to Defendant, and therefore, Defendant was not entitled to receive a new trial. View "State v. Leonard" on Justia Law

The Supreme Court affirmed in part and vacated in part the amended judgment of the superior court in favor of Plaintiff, as executor of the Estate of Armando Damiani (Mandy) and the Estate of Lillian Estrella, in this action alleging that Defendants had conspired to commit an unlawful conversion of funds in Mandy's investment account, holding that the portion of the amended judgment awarding Plaintiff compensatory damages and prejudgment interest was error.Specifically, the Supreme Court held (1) the trial justice erred by permitting a witness to testify despite knowing that she would invoke her privilege against self-incrimination under the Fifth Amendment, and the error prejudiced Defendant; and (2) there was no reason to disturb the trial justice's decision on Plaintiff's claim for declaratory judgment. View "Estrella v. Janney Montgomery Scott LLC" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Respondent, the tax assessor for the City of East Providence, and dismissing Petitioner's complaint brought pursuant to R.I. Gen. Laws 44-5-26(c) alleging that Respondent conducted an illegal property tax assessment for tax year 2012 and an excessive tax assessment for tax year 2013, holding that the superior court did not err.In moving for summary judgment Respondent asserted that Petitioner's claims fell outside the three-month statute of limitations contained in R.I. Gen. Laws 44-5-26 and 44-5-27. Petitioner appealed, arguing that the ten-year statute of limitations generally applicable to civil actions governed its tax assessment challenges. The Supreme Court disagreed and affirmed, holding (1) the General Assembly intended for the three-month statute of limitations to apply to petitions for relief such as the instant petition; and (2) Petitioner's challenges to the illegality of the 2012 and 2013 tax assessments were untimely filed after the three-month statute of limitations had expired. View "Newport & New Road, LLC v. Hazard" on Justia Law

The Supreme Court vacated the orders of the family court reopening a divorce case finalized by the family court more than two decades ago and awarding Steven Capaldi a portion of his pension to Anne Farrer, holding that the trial justice's decision granting Anne's motion for relief was incorrect as a matter of law.In 1993, the family court entered final judgment in the underlying divorce case. In 2017, Anne filed a motion for post-judgment relief seeking an award of one-half interest in the marital portion of Steven's pension on the ground that Steven "concealed" the pension at the time of the divorce. The trial justice granted relief. The Supreme Court vacated the decision below, holding that the statute of limitations in R.I. Gen. Laws 9-1-17 barred Anne's belated request to reopen the final judgment. View "Capaldi v. Capaldi" on Justia Law

The Supreme Court affirmed the decision of the family court determining and assigning marital property, sanctioning Defendant $50,000, and ordering a $16,000 credit to Plaintiff, holding that Defendant was not entitled to relief on his allegations of error.In 2000, the parties in this case married, and in 2017, the parties initiated divorce proceedings based on irreconcilable difference. At issue before the Supreme Court was the trial court's determination and equitable distribution of marital assets. After an eight-day trial, the trial justice issued a bench decision. Defendant appealed. The Supreme Court affirmed, holding that the trial justice (1) did not err in the determination and assignment of marital assets; (2) did not err in the imposition of sanctions; and (3) did not abuse her discretion in ordering a $16,000 credit to Plaintiff. View "DiDonato v. DiDonato" on Justia Law

The Supreme Court affirmed the judgments of the superior court convicting Defendant following a jury trial for larceny of an automobile and adjudicating him a probation violator, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued, among other things, that the trial court erred in denying his motion to suppress certain evidence collected as a result of a warrantless search of his real-time cell-site location information (CSLI). The Supreme Court disagreed and affirmed, holding (1) the acquisition of real-time CSLI qualifies as a search under the Fourth Amendment for which a warrant is required; (2) any error in the trial justice's determination that the exigent circumstances exception to the warrant requirement applied to the facts of this case was harmless; (3) the trial justice did not abuse his discretion in denying Defendant's motion to exclude certain testimony, and any error in allowing other testimony to be admitted at trial was harmless; and (4) Defendant waived his last argument for appeal. View "State v. Sinapi" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of five counts of first-degree robbery and three counts of conspiracy to commit robbery, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued that the trial court erred in failing to exclude statements he made during a post-arrest police interview and in denying his motion for a new trial. The Supreme Court disagreed and affirmed, holding (1) the trial justice did not abuse his discretion by admitting Defendant's statements about firearms as probative of his opportunity, intent, preparation, or plan to supply a weapon for the robberies and conspire to commit the robberies; and (2) the prejudice arising from Defendant's "highly relevant" statements substantially outweighed their probative value. View "State v. Reverdes" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Roger Williams Medical Center (RWMC) in this case alleging medical malpractice and negligent credentialing claims, holding that there was no error in the proceedings below.On appeal, Plaintiff argued that the motion justice erred in granting RWMC's motion for summary judgment on the ground that Plaintiff could not prove his negligent credentialing and medical malpractice claims without expert testimony. The Supreme Court affirmed, holding (1) expert testimony was required to prove Plaintiff's apparent agency claim against RWMC, and because Plaintiff failed to provide expert testimony, RWMC could not be held liable under an agency theory; and (2) Plaintiff's inability to present expert testimony establishing the standard of care applicable to RWMC in credentialing its doctors was fatal to Plaintiff's negligent credentialing claim. View "Dockray v. Roger Williams Medical Center" on Justia Law