Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of seven criminal offenses, including conspiracy to commit murder. The trial justice sentenced Defendant to consecutive life sentences plus twenty non-parolable years to run consecutively to the life sentences. The Supreme Court affirmed, holding (1) Defendant waived his arguments that the trial justice erred when he admitted certain evidence; and (2) the trial justice did not err by failing to dismiss the offense of discharging a firearm while in the commission of a crime of violence because, contrary to Defendant's assertions, the charge did not merge for double-jeopardy purposes with the offense of assault with a dangerous weapon with intent to murder. View "State v. Young" on Justia Law

After a jury trial, Defendant was convicted of multiple counts of felony assault and of using a firearm while committing a crime of violence and one count of carrying a pistol or revolver without a license. The Supreme Court affirmed on appeal, holding (1) the trial justice did not err in admitting a statement the victim made to police shortly after he was shot because the statement was relevant and the probative value of the evidence was not substantially outweighed by the danger of unfair prejudice; (2) the trial court did not deprive Defendant of his right to present a full defense, as Defendant was accorded leeway in presenting a third-party-perpetrator defense; and (3) the trial justice did not err in denying Defendant's motion for a new trial. View "State v. Covington" on Justia Law

Plaintiff fell and was injured on a sidewalk in the City of Providence. Plaintiff filed suit against the City and the State, alleging that it negligently failed to maintain or repair the sidewalk. The City moved for summary judgment, alleging that it did not owe a duty to Plaintiff because the State was responsible for the maintenance and repair of the sidewalk. In response, the State argued that a genuine issue of material fact existed as to whether the State or the city bore responsibility to maintain the sidewalk. The trial court granted summary judgment in favor of the City. The Supreme Court affirmed, holding that because the State did not assert a cross-claim against City, it was not sufficiently aggrieved by the entry of summary judgment in favor of the City on Plaintiff's claim to appeal from the superior court's judgment. View "Lombardi v. City of Providence" on Justia Law

Plaintiff filed suit against Defendant, one of his former law partners, after that law practice was dissolved. Plaintiff's complaint alleged intentional interference with prospective contractual relations, defamation, and corporate opportunity doctrine. The trial justice entered judgment against Plaintiff , finding that the evidence was insufficient as a matter of law to prove damages arising from the alleged tortious conduct of Defendant. The court subsequently denied Plaintiff's motion for a new trial. The Supreme Court affirmed, holding that the trial justice did not err (1) in concluding that damages for loss of reputation in a claim for tortious interference with a contract must be properly quantified; (2) in finding that the term "smoking gun" was not slanderous per se; and (3) in failing to submit Plaintiff's claim of breach of fiduciary duty to the jury. View "Bossian v. Anderson" on Justia Law

Defendant's employer had insurance through American States Insurance Policy (ASIC). After Defendant was involved in a car accident, Defendant sent ASIC written notice of a potential claim under ASIC's uninsured/underinsured (UM/UIM) coverage. ASIC did not formally deny the claim but, rather, responded with a declaratory-judgment action, asserting that because Defendant had failed to undertake legal action or to make a written demand for arbitration against ASIC within three years from the date of the accident, her UIM claim against ASIC was time-barred. The U.S. district court entered judgment on the pleadings in favor of ASIC, determining that the three-year limitations period set forth in the policy did not violate public policy. On appeal, the court of appeals certified a question of law to the Rhode Island Supreme Court, which answered by holding that Rhode Island would not enforce the contractual limitations clause in this case because it began to run on the date of the accident rather than the date the insurance contract was breached and was shorter than the statutory limitations period. View "Am. States Ins. Co. v. LaFlam" on Justia Law

At issue in this case was two properties consisting of neighboring condominiums. In 2005, Defendants placed barriers in Plaintiffs' claimed right of way, which impeded vehicle access and foot traffic. After Defendants refused to remove the barrier, Plaintiffs sued Defendants, alleging that, according to a condominium declaration, Plaintiffs had an express easement over the right of way, or, in the alternative, they had an implied or prescriptive easement over the right of way. After a trial, the trial justice ruled in favor of Defendants. The Supreme Court (1) vacated the judgment of the superior court with respect to its determination that Defendants did not have a claim of an implied easement by reservation over the right of way, as the trial justice did not make any findings or legal conclusions with respect to whether Plaintiffs had an implied easement by grant over the claimed right of way; and (2) affirmed in all other respects. Remanded. View "Wellington Condo. Ass'n v. Wellington Cove Condo. Ass'n" on Justia Law

After a bench trial, Defendant was convicted of criminal counts, including larceny, assault with a dangerous weapon, and violation of a protective order. Defendant appealed, arguing, among other things, that the State failed to comply with the Interstate Agreement on Detainers Act (IADA), and therefore, the trial court erred when it did not dismiss the charges against him. The Supreme Court affirmed the convictions, holding (1) the trial court did not err in denying Defendant's motion to dismiss, as Defendant forfeited his IADA argument for failing to raise it before the deadline expired; and (2) Defendant's convictions for both larceny and assault with a dangerous weapon did not violate the Double Jeopardy Clauses of the state and federal constitutions. View "State v. Oliver " on Justia Law

Defendant pled nolo contendere to assault with a dangerous weapon. The trial justice sentenced Defendant to twenty years incarceration, with ten years to serve and ten years suspended with probation. One year after Defendant unsuccessfully moved for a sentence reduction under R.I. R. Crim. P. 35, Defendant filed a motion requesting the trial justice assign for a hearing the previously filed Rule 35 motion. After a hearing, the trial justice granted the motion and amended Defendant's sentence to twenty years, nine years to serve and eleven years suspended with probation. The Supreme Court quashed the superior court's judgment modifying Defendant's term to serve, holding that Defendant's motion to reduce sentence/assign pursuant to Rule 35 was not properly before the trial court because, notwithstanding the language contained within the text of that motion, the filing was an untimely filed new motion, and therefore, the trial justice erred in granting the motion. View "State v. Keenan" on Justia Law

After a jury trial, Defendant was convicted of first degree sexual assault. The Supreme Court affirmed the conviction, holding that the trial court did not err in (1) declining to dismiss the indictment based upon a partially inaudible and incomplete grand jury record, as an unintentional failure to record or reproduce the grand jury proceedings does not affect the validity of the prosecution; (2) denying Defendant's motion to pass the case based upon Sup. Ct. R. Crim. P. 16 violations by the state, where a violation of Rule 16 occurred in this case, but the nondisclosures were not deliberate on the part of the prosecutor; and (3) admitting the testimony of an expert in the field of sexual abuse, as the testimony did not constitute impermissible vouching or bolstering of other fact witnesses. View "State v. Huffman" on Justia Law

Defendant was indicted for several sex-related crimes. Defendant opted to exercise his constitutional right to represent himself. After the jury was sworn, Defendant expressed his desire to absent himself from the trial in the event a plea agreement was not reached. The trial continued in Defendant's absence. The jury subsequently found Defendant guilty of three counts of first-degree child molestation sexual assault and two counts of first-degree sexual assault. Defendant appealed, contending, among other things, that the trial justice was constitutionally required to appoint counsel to represent him when he absented himself from trial. The Supreme Court affirmed, holding (1) Defendant validly waived his right to counsel; (2) the trial justice did not abuse his discretion in denying Defendant's post-waiver request for counsel; (3) the trial justice was not constitutionally required to appoint counsel to represent Defendant after he chose to proceed pro se and then absented himself from trial; and (4) Sup. Ct. R. Crim. P. 43 did not present any bar to Defendant's trial continuing, even after he elected not to be present. View "State v. Eddy" on Justia Law