Justia Rhode Island Supreme Court Opinion Summaries

Plaintiff was a condominium unit owner in a condominium community comprised of three sub-condominium residential areas. Plaintiff filed an application for approval to demolish his existing unit and rebuild a larger unit. After America Condominium Association asserted that Plaintiff did not own the land on which he sought to expand, Plaintiff filed a complaint against America seeking a declaratory judgment that he had sufficient interest to file an application regarding the expansion of his unit onto adjoining land. Plaintiff then brought an action against the larger condominium association and the other sub-condominium associations in the community, essentially parroting the allegations set forth in the America action. In both actions, the hearing justice concluded that Plaintiff had standing to file his application for the expansion of his unit but that Plaintiff's proposed expansion required the unanimous consent of the other 153 unit owners. The Supreme Court primarily affirmed, holding (1) Plaintiff had standing to file the application for expansion; but (2) pursuant to the Condominium Act, the unanimous consent of all of the unit owners must be obtained before Plaintiff could carry out his unit expansion. View "Sisto v. Am. Condo. Ass'n" on Justia Law

Wife filed for a divorce from Husband. Thereafter, Husband unsuccessfully filed a motion to dismiss the complaint, contending that the family court did not have jurisdiction because Wife had not been a resident of the State for one year prior to the filing of the complaint. In the meantime, Wife filed an emergency motion for seeking an order restraining Husband from proceeding with a divorce action in any other jurisdiction, which the trial justice granted. After a trial, the trial justice sanctioned Husband for violation of a discovery order, distributed the martial property, found Wife was entitled to rehabilitative alimony, ordered that Husband should pay Wife counsel fees, and found that Husband was in contempt of court because he violated the prior order restraining him from proceeding with a divorce in another jurisdiction. The Supreme Court affirmed, holding that the trial justice did not err (1) in denying Husband's motion to dismiss for lack of subject matter jurisdiction, as Wife residency in the State met the subject matter jurisdiction requirements of the pertinent statute; (2) in awarding Wife rehabilitative alimony; (3) with respect to the award of counsel fees; and (4) in his adjudication of Husband as being in contempt of court. View "Meyer v. Meyer" on Justia Law

Wife filed a complaint for an absolute divorce, and Husband filed a counterclaim. As grounds for divorce, both parties cited irreconcilable differences. The proceedings in the family court spanned almost five years. The family court eventually granted Wife's complaint. At issue on appeal was the court's distribution of the stock of Microfibres, Inc. (Microfibres), of which Husband was the president and CEO, and Microfibres Partnership Limited (MPL). The Supreme Court (1) affirmed the portion of the family court's decision addressing the portion of MPL that was marital property and the trial justice's grant of partial summary judgment holding that the stock of Microfibres was marital property; and (2) vacated the portion of the decision addressing the equitable distribution of the marital estate, holding that the trial justice erred when he declined to value his assignments of Microfibres and MPL. Remanded with direction to value Microfibres and MPL as of the date of trial and to distribute the marital estate in accordance with R.I. Gen. Laws 15-5-16.1. View "McCulloch v. McCulloch" on Justia Law

Plaintiff was an inmate serving a life sentence incarcerated at the Adult Correction Institutions (ACI). Plaintiff filed an amended complaint naming as defendants employees of the ACI and Department of Corrections (DOC), alleging that Defendants violated his right to privacy by monitoring him via video camera while he was in his prison cell and that Defendants regularly harassed him. The trial justice dismissed the complaint. The Supreme Court affirmed. Meanwhile, Plaintiff filed another complaint against thirteen employees of the DOC. Along with the complaint, Plaintiff filed a motion to proceed in forma pauperis. The trial court denied Plaintiff's motion and entered an administrative order restricting Plaintiff from filing any further pro se actions in superior court. The Supreme Court vacated the orders restricting Plaintiff from filing any pro se actions, holding that the order did not comport with Supreme Court precedent and impermissibly infringed upon Plaintiff's right of access to the courts. View "Laurence v. R.I. Dep't of Corr." on Justia Law

Buyers purchased real estate and retained Attorneys in connection with their purchase. Buyers sued Attorneys, alleging that, due to Attorneys' negligence, they overpaid Seller by more than $1,700,000. Attorneys filed a motion for leave to file a third-party complaint naming Agents as third-party defendants, alleging that Agents had a fiduciary duty to both Seller and Buyers and that if Buyers were entitled to recover for their alleged damages, then Agents would be liable for all or part of Buyers' claims against Attorneys. The superior court granted the motion. A motion justice subsequently granted Agents' motions to dismiss the third-party complaint, finding that the third-party complaint failed to plead a duty owed by Agents to either Buyers or Attorneys. The Supreme Court disagreed and vacated the superior court's subsequent denial of Attorneys' second motion for leave to file a third-party complaint, holding that Attorneys' second proposed third-party complaint fell within the scope of R.I. R. Civ. P. 14, which governs impleader. View "Wampanoag Group, LLC v. Iacoi" on Justia Law

After a trial at which he represented himself, Defendant was convicted of kidnapping, domestic felony assaults, intimidation of a witness, and violation of a no-contact order. The Supreme Court affirmed the convictions. Defendant subsequently filed several motions, which the superior court treated as a subsequent application for postconviction relief and then denied. In the motions, Defendant argued, inter alia, that the prosecutor erred in failing to produce certain victim-impact statements in response to his discovery requests. The Supreme Court affirmed, holding (1) even if the claims underlying this postconviction relief application were not barred by res judicata, they were meritless; (2) even if the State had disclosed the victim-impact statements to Defendant before trial, Defendant failed to demonstrate that the result of his trial would have been different, and therefore, Defendant's claim that the State violated Brady v. Maryland failed; (3) Defendant was not prejudiced by the State's failure to disclose the victim-impact statements under R.I. R. Evid. 16; and (4) Defendant was not entitled to postconviction relief based on newly discovered evidence. View "State v. Thornton" on Justia Law

After a jury trial, Defendant was convicted of simple domestic assault. The Supreme Court affirmed the judgment of conviction, holding that the trial justice (1) did not err in giving a jury instruction with respect to intent; (2) did not err in limiting Defendant's constitutional right to cross-examination of the complainant; (3) did not err in allowing a witness to express his opinion that Defendant was the aggressor because even if the testimony consisted of impermissible vouching, the admission of the testimony did not constitute prejudicial error; and (4) Defendant failed to establish any prejudice arising from the complainant's email having been read into the record rather than having been marked as an exhibit or otherwise provided to Defendant. View "State v. Kausel" on Justia Law

While on probation, Defendant fled from two police officers. After Defendant was arrested, a firearm was discovered on the floor of his car. A trial justice later found Defendant to be a violator of the terms and conditions of his probation. In addition to the probation-violation proceeding, the State charged Defendant with recklessly operating a motor vehicle, carrying a revolver without a license, and possession of a firearm after having been convicted of a crime of violence. During the course of the violation hearing, the State requested, in a motion in limine, that the trial justice interpret the Firearms Act in such a manner that a weapon need not be capable of expelling a projectile to fit within the definitions of "firearm" or "pistol." The trial justice denied the motion. The Supreme Court affirmed, holding (1) the trial justice did not err in finding that Defendant violated the terms of his probation; and (2) the trial justice correctly denied the State's motion in limine. View "State v. Hazard" on Justia Law

After a jury trial, Defendant was convicted of first degree child abuse for inflicting serious bodily injury on his infant son. Defendant was sentenced to twenty years incarceration. The Supreme Court affirmed the conviction, holding (1) the trial justice correctly denied Defendant's challenge to the constitutionality of the child abuse statute; (2) the trial justice did not err when he admitted a statement that Defendant wrote at the police station because Defendant knowingly and voluntarily waived his Miranda rights before providing the statement; and (3) the trial justice did not err in denying Defendant's motion for a judgment of acquittal and his motion for a new trial. View "State v. Allen" on Justia Law

The Providence School Board (Board) provided health insurance to active employees and retirees. In 2006, the Providence Teachers Union (Union) filed a grievance protesting a difference in the increase of premium costs for retirees compared with a more modest increase in premium costs for active employees. The Union argued that the Board's action violated three provisions of the collective bargaining agreement (CBA) between the board and the union. An arbitrator ruled in the Union's favor, concluding that the Board violated the CBA by failing to include retirees and active employees in a single group when it calculated the healthcare premium rates. The trial justice vacated the arbitration award, concluding (1) the Union did not have standing to pursue a grievance on behalf of retirees, and (2) the issue of the calculation of the group premium rate was not arbitrable. The Supreme Court affirmed, holding (1) pursuant to Arena v. City of Providence and City of Newport v. Local 1080, the Union could not pursue this grievance on behalf of the retirees; and (2) because the Union had no standing to pursue this particular grievance, the grievance was not arbitrable. View "Providence Sch. Bd. v. Providence Teachers Union, Local 958" on Justia Law