Justia Rhode Island Supreme Court Opinion Summaries

Plaintiff filed this negligence action against Defendant, a medical doctor, seeking damages for injuries she sustained after she fell on an entrance ramp to Defendant's podiatric officers during a winter storm. The superior court granted summary judgment for Defendant, concluding (1) there was no dispute that the storm on the day of Plaintiff's fall included snow; (2) Defendant was justified to wait until the storm ended before taking action to treat his office entrance; and (3) Defendant did not owe Plaintiff or other invitees a heightened duty of care. The Supreme Court vacated the lower court's judgment and remanded, holding (1) because the parties disagreed as to the extent of the storm on the day of Plaintiff's fall, additional factual findings were required to determine whether Defendant was under a duty to treat his entranceway before the storm had ended, and thus, the grant of summary judgment was improper; and (2) Defendant did not owe Plaintiff a heightened duty of care. View "Sullo v. Greenberg" on Justia Law

After a jury trial, Defendant was convicted of one count of possession of marijuana and two counts of possession of cocaine with the intent to deliver while armed with or having available a firearm. Defendant appealed, arguing, among other things, that the trial justice erred in permitting the State to impeach his credibility with an allegation of previous criminal conduct and with information that was false and prejudicial. The Supreme Court vacated the judgment of conviction, holding (1) the trial court's questions concerning the nature of the offense with which Defendant was previously charged were improper and inappropriate for impeachment purposes because not only did these questions place factually incorrect information before the jury, but they impermissibly introduced false evidence of Defendant's previous criminal conduct; and (2) the error was not harmless. View "State v. Price" on Justia Law

After a jury trial, Defendant was convicted of first-degree child molestation. Defendant appealed, contending (1) the trial justice erred in denying his motion to suppress a statement he made to the police as the fruit of an unlawful arrest, and (2) the trial justice erred in admitting the statement without first redacting certain portions. The Supreme Court affirmed, holding (1) because Defendant was validly arrested, and because the trial justice did not err in concluding that Defendant knowingly, voluntarily, and intelligently waived his Miranda rights, the court properly denied Defendant's suppression motion; and (2) the trial justice did not err in refusing to redact Defendant's statement to police. View "State v. Morin" on Justia Law

After a jury trial, Defendant was convicted of first-degree sexual assault. Defendant appealed, contending that the trial justice erred in (1) refusing to give Defendant's requested jury instructions on the defense of consent, (2) admitting certain testimony under the excited-utterance exception to the hearsay rule, and (3) denying his motion to dismiss the indictment due to irregularities in the grand jury proceedings. The Supreme Court affirmed, holding that the trial justice (1) did not err in refusing to instruct the jury on a consent defense that was unsupported by any of the testimony given at trial; (2) did not abuse its discretion in admitting the testimony under the excited-utterance exception to the hearsay rule; and (3) did not err in denying Defendant's request to dismiss the indictment, as any error that may have occurred during the grand jury proceeding was harmless. View "State v. Martin" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, three counts of using a firearm while committing a crime of violence, burglary, and two counts of assault with a dangerous weapon. Defendant appealed, arguing that the trial justice erred in refusing to admit evidence about the alleged drug possession and intoxication of certain of the state's witnesses and in allowing into evidence prejudicial information about Defendant's parole status. The Supreme Court affirmed, holding that the trial justice (1) did not abuse his discretion in limiting the cross-examination of the witnesses' alleged drug use and possession; (2) correctly ruled that evidence of the witnesses' possible intoxication was inadmissible because it did not rise to the level of intoxication; and (3) did not abuse his discretion in permitting the references to Defendant's parole status. View "State v. Bishop" on Justia Law

Petitioner filed a petition to foreclose the right of redemption arising from a tax sale of certain property. The petition indicated that Respondents, including Perfecto Iron Works, held an interest in the property and that Respondents were provided notice of the petition. Neither Petitioner nor her attorney received a copy of Perfecto's answer, and thus, believing no responsive pleading had been filed, Petitioner filed a motion for entry of default. After a hearing, a final decree was entered vesting legal and equitable title to the property in Petitioner. Perfecto subsequently filed a motion to vacate the default and final decree. A trial justice granted the motion, concluding that the default was erroneously entered because Perfecto's answer was timely filed. The Supreme Court affirmed, holding that the trial justice properly vacated the default decree when, in fact, Perfecto had answered the petition and had done so in a timely manner. View "Rafaelian v. Perfecto Iron Works, Inc." on Justia Law

RICS executed a note secured by a mortgage on real estate. Meanwhile, TLA entered into a contract with RICS to provide architectural and engineering services for the project and recorded two documents related to its work on the project. Subsequently, TLA filed a petition to enforce its mechanics' lien. No claimant timely entered an appearance in TLA's mechanics' lien litigation to preserve the priority of their claims. Months later, Petra purchased the note and mortgage, which had not been recorded by the previous owner. Meanwhile, the superior court entered a consent order signed by RICS and TLS in the mechanics' lien litigation. RICS subsequently conveyed the property, and the court placed the property into receivership. Petra later filed a motion to file an answer and statement of claim out of time in the mechanics' lien proceedings. The court granted the motion, thereby restoring the mortgage's priority over TLA's mechanics' lien. The property was sold to Petra through a receivership action. The Supreme Court reversed the superior court's grant of Petra's motion, thereby restoring the priority of TLA's mechanics' lien, holding that the motion justice erred in determining that Petra's failure to file a timely statement of claim was the result of "excusable neglect." View "R.I. Constr. Servs., Inc. v. Harris Mill, LLC" on Justia Law

At issue in this appeal was the interpretation of a clause concerning the allocation of real estate taxes contained in a written lease between Inland American Retail Management and Cinemaworld of Florida. Inland and Cinemaworld were successors-in-interest to a ground lease for the rental of what is now a movie theater in a shopping center. Under the terms of the lease, Cinemaworld incurred certain liabilities and expenses. Pursuant to a clause in the lease, Cinemaworld was required to pay an amount equal to the real estate taxes "levied, assessed, or otherwise imposed" against the movie theater. Inland filed a complaint for breach of the lease for Cinemaworld's alleged failure to make timely payments as required by the lease. The superior court granted partial summary judgment in Cinemaworld's favor with respect to its motion seeking an accounting, ruling that the formula allocating Cinemaworld's reasonable share of real estate taxes should be based on the square footage of its leased premises. Inland appealed. The Supreme Court vacated the judgment of the superior court, holding that there was a genuine issue of material fact as to the interpretation of the parties' lease. View "Inland Am. Retail Mgmt. LLC v. Cinemaworld of Fla., Inc." on Justia Law

After Evelyn was born, Father and Mother tested positive for cocaine, opiates, and marijuana. Eventually, the family court found both parents were unfit due to chronic drug use and terminated the parental rights of Father to Evelyn. Father appealed. The Supreme Court affirmed, holding (1) ample evidence supported the trial justice's finding that Father had a chronic substance abuse problem that rendered him unable to care for Evelyn; and (2) the evidence was sufficient to support the trial court's determination that it was unlikely Evelyn could be returned to Father within a reasonable amount of time. View "In re Evelyn C." on Justia Law

In 1995, Elizabeth Meyer, the sole shareholder and CEO of Greensleeves, Inc., orally agreed to buy six dock slips from Philip Smiley. Smiley subsequently entered into a purchase and sale agreement with Eugene Friedrich for the sale of those same dock slips. When Smiley refuse to convey the dock slips to Greensleeves, Greensleeves filed suit against Smiley. Friedrich intervened and moved to dismiss the complaint. The superior court granted judgment in favor of Smiley and Friedrich, finding no enforceable contract between Greensleeves and Smiley. The Supreme Court vacated the superior court's judgment, holding that there was an enforceable contract between Greensleeves and Smiley. Friedrich subsequently relinquished his ownership of the dock slips and conveyed them to Greensleeves. Greensleeves then sought an accounting of the rental income that had been collected from the dock slips from the date of the originally-scheduled closing between Greensleeves through the 1999 boating season. Ultimately, the trial court concluded (1) Friedrich had tortiously interfered with the contract between Smiley and Greensleeves, and (2) Greensleeves was entitled to lost rental profits of $61,258 plus interest and costs. The Supreme Court affirmed, holding that the trial court did not commit reversible error in its findings and judgment. View "Greensleeves, Inc. v. Smiley" on Justia Law