Justia Rhode Island Supreme Court Opinion Summaries
Siemens Fin. Servs., Inc. v. Stonebridge Equip. Leasing, LLC
Plaintiffs agreed to lease medical diagnostic imaging equipments to Defendants for use in a medical imaging center. The center proved to be unsuccessful shortly after it opened, and Defendants defaulted on their payments. Plaintiffs filed a fourteen-count complaint against Defendants that included counts for replevin, breach of contract, breach of consent to sublease, and breach of sublease. Defendants counterclaimed for intentional misrepresentation, negligent misrepresentation, fraud and deceit, and a violation of Mass. Gen. Laws ch. 93A. The superior court granted summary judgment for Plaintiffs on all claims and counterclaims. The Supreme Court affirmed, holding that there were no genuine issues of material fact, and therefore, summary judgment was proper on Plaintiffs’ claims and Defendants’ counterclaims. View "Siemens Fin. Servs., Inc. v. Stonebridge Equip. Leasing, LLC " on Justia Law
Posted in:
Contracts
R.I. Joint Reinsurance Ass’n v. O’Sullivan
At issue in this case was which party was entitled to insurance funds under an insurance policy on a parcel of property that sustained water damage. Stanley Gurnick and Phoenix-Gurnick, RIGP claimed they owned the property as a result of a foreclosure sale. Navigant Credit Union claimed it was entitled to the funds as the named mortgagee/loss payee in the insurance policy. The superior court decided that Navigant was entitled to the insurance proceeds because the funds were personal property under the insurance contract and Navigant was named a loss payee under that contract. The Supreme Court affirmed, holding that the hearing justice correctly determined that Navigant was entitled to the insurance proceeds. View "R.I. Joint Reinsurance Ass’n v. O’Sullivan" on Justia Law
Bober v. Bober
After a trial, the family court dissolved the twenty-four year marriage of Husband and Wife. Both parties appealed the family court’s decision. The Supreme Court affirmed in part and reversed in part the decision pending entry of final judgment, holding that the trial justice (1) did not overlook or misconceive the medical evidence relating to Wife’s medical condition; (2) did not err in distributing the property; (3) did not err by retroactively applying a modification of child support; (4) did not err by failing to award Wife lifelong medical coverage and attorney’s fees; and (5) made an inequitable sua sponte modification concerning the termination of alimony.
View "Bober v. Bober" on Justia Law
Posted in:
Family Law
Woodruff v. Gitlow
The Federal Aviation Administration (FAA) requires that all pilots obtain and maintain a valid medical certificate. After he was involved in motor-vehicle accident, Plaintiff, a commercial pilot, surrendered his medical certificate at the request at the FAA. Plaintiff subsequently sought reinstatement from the FAA. The FAA retained Defendant, a physician, as a medical consultant to opine whether Plaintiff met the FAA’s criteria for alcohol dependence. After reviewing certain medical documents, Defendant determined that Plaintiff was substance dependent. Plaintiff sued Defendant, alleging that Defendant was negligent in making his report and that the FAA had relied on Defendant’s conclusion to Plaintiff’s detriment. The superior court denied Defendant’s motion for summary judgment, concluding that Defendant owed Plaintiff a duty of care to accurately reach or report the conclusions of his records review. The Supreme Court quashed the order of the superior court, holding that Defendant did not owe Plaintiff a duty of care in this case. View "Woodruff v. Gitlow" on Justia Law
Posted in:
Injury Law
Santos v. State
In 1998 after a plea hearing, the hearing justice accepted Amadeu Santos’s plea of nolo contendere to three counts of second-degree sexual assault. In 2012, Santos filed an application for postconviction relief, asserting that the 1998 plea colloquy did not comply with the Superior Court Rules of Criminal Procedure. The hearing justice denied Santos’s application, finding that it was barred by the doctrine of laches. The Supreme Court affirmed, holding that the hearing justice’s decision regarding the unreasonableness of Santos’s delay was not clearly wrong, nor did it constitute an abuse of discretion. View "Santos v. State" on Justia Law
Posted in:
Criminal Law
Rosano v. Mortgage Elec. Registration Sys., Inc.
Plaintiff executed a promissory note in favor of EquiFirst, secured by a mortgage on real estate. The mortgage designated EquiFirst as the Lender and named Mortgage Electronic Registration Systems (MERS) as the mortgagee and the Lender’s nominee. MERS, as EquiFirst’s nominee, assigned the mortgage to Sutton Funding, which assigned the mortgage to Bank of New York Mellon Trust Company (Bank of New York). Bank of New York subsequently initiated a foreclosure sale, at which it prevailed as the highest bidder. Plaintiff filed suit in the superior court challenging the validity of the two mortgage assignments. The hearing justice dismissed Plaintiff’s complaint under Sup. Ct. R. Civ. P. 12(b)(6), concluding that the assignments were valid, and additionally dismissed Plaintiff’s complaint under Rule 12(b)(7) for failing to join an indispensible party, Bank of New York. The Supreme Court affirmed the dismissal on the basis of Rule 12(b)(7), holding that hearing justice’s dismissal on Rule 12(b)(7) grounds was appropriate where Plaintiff failed to join Bank of New York to the action. View "Rosano v. Mortgage Elec. Registration Sys., Inc." on Justia Law
Posted in:
Banking, Real Estate & Property Law
State v. Ferrer
After a jury trial, Defendant was convicted of carrying a pistol without a license and possession of a firearm by a person previously convicted of a crime of violence. The Supreme Court affirmed the judgment of conviction, holding (1) the trial justice did not err in denying Defendant’s motion for a judgment of acquittal because the the State produced sufficient evidence at trial from which a jury could infer beyond a reasonable doubt that Defendant possessed the handgun; and (2) the trial justice did not violate Defendant’s right to effective assistance of counsel by restricting defense counsel’s closing argument. View "State v. Ferrer" on Justia Law
Joseph P. Notarianni Revocable Trust v. Notarianni
Decedent established a Trust that required, upon Decedent’s death, the trustee to distribute a parcel of land to the trustee and to distribute the remainder of the land to Decedent’s children. The Trust filed a complaint for eviction for unlawfully holding over after the termination of tenancy against Defendants, Decedent’s children. The district court entered judgment in favor of the Trust. Defendants appealed, arguing that the Trust was not a landlord and Defendants were not tenants, but rather, tenants in common with the trustee. Therefore, Defendants argued, an action for eviction could not lie. The superior court granted Defendants’ motion to dismiss, concluding that the court lacked subject matter jurisdiction and that the Trust lacked standing. The Supreme Court vacated the judgment of the superior court, holding that the superior court did have jurisdiction over trespass and ejectment matters, and therefore, the motion justice erred in dismissing the case for lack of subject matter jurisdiction. Remanded for an evidentiary hearing with respect to the issue of standing. View "Joseph P. Notarianni Revocable Trust v. Notarianni" on Justia Law
State v. Marte
After a jury trial, Defendant was convicted of possession with intent to deliver cocaine. Defendant appealed, arguing that the trial court erred by not excluding evidence that he was carrying cash at the time of his arrest and in denying him any remedy for the State’s late disclosure of that evidence. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not abuse its discretion in admitting the evidence, as the fact that Defendant had some amount of cash on his person at the time of the arrest was not unfairly prejudicial evidence. View "State v. Marte" on Justia Law
Posted in:
Criminal Law
In re Proceedings to Establish a Contact Voltage Detection & Repair Program
Power Survey Company sought a writ of certiorari before the Supreme Court contending that the Public Utilities Commission improperly interpreted and applied the Contact Voltage Statute when it approved the portion of the Narragansett Electric Company’s (NEC) contact voltage program providing for the issuance of a request for proposal for the purpose of choosing a vendor to provide the technology for the NEC’s contact voltage testing. The Supreme Court issued the writ. Respondents, the NEC and the Division of Public Utilities and Carriers, moved to quash the writ on the grounds that it was not timely filed. The Supreme Court granted Respondents’ motions, holding that, under the facts of this case, Power Survey’s petition was untimely. View "In re Proceedings to Establish a Contact Voltage Detection & Repair Program" on Justia Law