Justia Rhode Island Supreme Court Opinion Summaries

After unsuccessfully seeking reimbursement from the State Commissioner of Elementary and Secondary Education, Plaintiffs, a school district and school department, filed a complaint in the superior court alleging that the Commissioner and State Treasurer were required to reimburse them for the salary, fringe benefits, and travel expenses of the directors and guidance counselors in their vocational-technical programs. The superior court dismissed the complaint, concluding that Plaintiffs had an adequate remedy at law and that the Commissioner’s decision to deny Plaintiffs reimbursement was discretionary in nature, rather than ministerial. Plaintiffs subsequently sought a writ of mandamus. The Supreme Court affirmed the judgment of the superior court, holding that Plaintiffs did not have a clear legal right to be reimbursed for certain costs associated with the operation of their career and technical centers. View "Chariho Reg’l Sch. Dist. v. Gist" on Justia Law

After a jury trial, Defendant was convicted of one count of voluntary manslaughter. Defendant appealed the trial justice’s denial of her motion for a new trial, arguing that the State failed to meet its burden of proving beyond a reasonable doubt that she did not act in self-defense when she killed the victim. The Supreme Court affirmed the superior court’s judgment of conviction, holding that the trial justice did not overlook or misconceive material and relevant evidence and was not otherwise clearly wrong in her denial of Defendant’s motion for a new trial. View "State v. Garrett" on Justia Law

Defendant was charged with two counts of first-degree robbery in connection with two armed robberies. Defendant filed several motions to suppress evidence obtained by police detectives following his arrest. A hearing justice granted Defendant’s motion to suppress certain evidence under the exclusionary rule to the Fourth Amendment to the United States Constitution because the evidence was gathered after an “illegal” extra-jurisdictional arrest. The Supreme Court vacated the order of the superior court, holding (1) the detectives’ actions in arresting Defendant outside their jurisdiction were in excess of their authority; but (2) the exclusionary rule of the Fourth Amendment did not mandate the suppression of the evidence obtained in this case. View "State v. Morris" on Justia Law

After a jury-waived trial, Defendant was convicted of one count of domestic felony assault and one count of domestic simple assault. On appeal, Defendant argued, among other things, that the trial justice erred in denying his motion to dismiss the criminal information, which contained the two counts on which Defendant was convicted. The Supreme Court affirmed, holding (1) the criminal information was sufficient to establish probable cause for the two counts for which Defendant was convicted; and (2) the trial justice did not commit any evidentiary errors during the course of the trial. View "State v. Ceppi" on Justia Law

Son was born to Mother, who was incarcerated at the time of the birth. Father was also incarcerated at that time. The Department of Children, Youth, and Families (DCYF) filed a petition to terminate the parental rights of both parents, alleging that Mother and Father had chronic substance-abuse problems and that Son had been placed in the legal custody of DCYF for at least twelve months with no substantial probability that Son would be able to return to the parents’ custody within a reasonable period of time. After a hearing, the hearing justice terminated Father’s parental rights. The Supreme Court affirmed the decree terminating Father’s parental rights, holding (1) the trial justice did not abuse his discretion in finding that Father was unfit and that it was improbable that Son would be able to return to Father’s care within a reasonable period of time; and (2) the trial justice did not clearly err in finding that DCYF had met its burden to make reasonable efforts under R.I. Gen. Laws 15-7-7(b)(1). View "In re Lyric P." on Justia Law

Plaintiffs purchased a home. To finance the transaction, Plaintiffs executed a note payable to Accredited Home Lenders. The note was secured by a mortgage on the property naming Mortgage Electronic Registration Systems, Inc. (MERS) as the mortgagee. MERS assigned the mortgage to Deutsche Bank National Trust Company. Because Plaintiffs stopped making their payments as set forth in the note Deutsche Bank foreclosed on the property. Accredited REO Properties purchased the property. Plaintiffs subsequently filed a complaint seeking declaratory judgment and injunctive relief seeking orders declaring that they were owners of the property as a matter of law and that the foreclosure sale, conveyance, and assignment were void. Defendants - MERS, Deutsche Bank, Accredited REO Properties, Accredited Home Lenders, and others - filed a motion for summary judgment, which the district court granted. The Supreme Court affirmed, holding that a legal and valid foreclosure occurred in this case. View "Moura v. Mortgage Elec. Registration Sys., Inc." on Justia Law

After a jury trial, Defendant was found guilty of two counts of first-degree child molestation sexual assault. Defendant subsequently moved for a new trial, asserting that the verdict failed to respond to the evidence and failed to do substantial justice between the parties. The trial justice denied Defendant’s motion for a new trial. On appeal, Defendant challenged only the trial justice’s denial of his motion for a new trial. The Supreme Court affirmed the judgment of conviction, holding that the trial justice did not overlook or misconceive the material evidence and conducted the proper analysis in denying Defendant’s motion. View "State v. Lake" on Justia Law

Frederick Carrozza, Sr. filed a petition seeking to impose a resulting trust on four properties and caused notices of lis pendens to be filed with respect to each of the properties at issue. Counterclaimants, in turn, filed a counterclaim alleging slander of title. Summary judgment was granted in favor of Counterclaimants with respect to the resulting trust issue. After a trial on the slander of title counterclaim, the trial justice held the counterclaim defendants - Frederick Sr. and his three living children - liable for slander of title. The Supreme Court affirmed the judgment of the superior court in all respects except that part of the judgment awarding $845,00 in punitive damages, holding that the award of punitive damages should be reduced to $422,500. View "Carrozza v. Voccola" on Justia Law

David Alba was appointed to serve as principal of an elementary school in Cranston, Rhode Island. Alba and the Cranston School Committee subsequently entered into an employment contract. Later, after a hearing, the Committee rejected a recommendation to renew Alba’s employment contract. Alba appealed the Committee’s decision. The Commissioner of Education denied and dismissed Alba’s appeal, concluding that Alba had received all the process to which he was entitled under the contract and the School Administrators’ Rights Act. The Board of Regents affirmed the Commissioner’s decision. The Supreme Court affirmed, holding (1) the Committee acted within its authority when it voted against the recommendation to renew Alba’s contract; and (2) the Committee’s nonrenewal of Alba’s contract did not deprive Alba of his rights under the Administrators’ Rights Act. View "Alba v. Cranston Sch. Comm." on Justia Law

In 1990, Appellant was convicted of several criminal charges. Appellant was sentenced to thirty years’ imprisonment, with fifteen years to serve and fifteen years suspended. After Appellant was released from prison a justice of the superior court determined that Appellant had violated the terms and conditions of his probation and vacated the suspension of the remaining fifteen years of Appellant’s original sentence. One year later, Appellant filed an application for postconviction relief. An attorney was appointed to represent Appellant in his application but later filed a motion to withdraw, asserting that Appellant’s grounds for relief lacked merit. After a hearing, the attorney was allowed to withdraw. Appellant’s application for postconviction relief was ultimately denied. Appellant appealed, arguing that the hearing justice erred when she allowed Appellant’s attorney to withdraw. The Supreme Court affirmed, holding that the hearing justice was not clearly wrong and did not overlook or misconceive material evidence when she concluded that Appellant’s application lacked merit and granted Appellant’s attorney’s motion to withdraw. View "Roscoe v. State" on Justia Law