Justia Rhode Island Supreme Court Opinion Summaries

In 2009, three men attacked and robbed Complainant. Several days later, Complainant saw one of his attackers loitering on the street. After a foot chase, Complainant caught the attacker - Michael Long - and held him until the police arrived. Upon his arrest, Long implicated Defendant in the crime. After a jury trial, Defendant was convicted of one count of first-degree robbery. The Supreme Court affirmed the conviction, holding (1) Defendant waived his double jeopardy challenge; (2) the trial justice did not abuse her discretion by admitting Long’s prior police statement as a prior inconsistent statement, and the use of Long’s prior police statements as prior inconsistent statements did not violate the Confrontation Clause; (3) any use of leading questions posed to Long by the prosecutor was harmless; (4) the trial justice did not err by admitting Long’s statements to his former finacee in the presence of Defendant as adoptive admissions; and (5) the trial justice did not err by denying Defendant’s motion for a new trial. View "State v. Matthews" on Justia Law

Plaintiff, a member of the Rhode Island National Guard, was hired by the Department of Corrections (DOC) in 1988. In 2000, Plaintiff left his full-time employment at the DOC to report for active duty with the National Guard. Plaintiff returned to the DOC after having been on military leave for six years. In 2003, Plaintiff filed a declaratory judgment action against the DOC, contending that he was subjected to discrimination based on his military status when the DOC denied him promotion on three separate occasions during the six-year period when he was on military leave. The superior court entered judgment in favor of the DOC. The Supreme Court affirmed, holding (1) the trial justice did not err in denying Plaintiff’s claim for a declaratory judgment where Plaintiff failed to show that his military status or resulting unavailability was a substantial or motivating factor in the DOC’s repeated decisions not to promote him; and (2) the trial justice did not overlook or misconceive relevant and material evidence in the case. View "Panarello v. State, Dep’t of Corr." on Justia Law

Plaintiffs, limited liability entities that owned property in the Town of Coventry, filed suit seeking declaratory and injunctive relief challenging the legality of sewer assessments assessed by Coventry. A hearing justice dismissed Plaintiffs’ complaint for their failure to follow the correct administrative appeal process. The Supreme Court vacated the judgment of the superior court dismissing Plaintiffs’ complaint, holding (1) the hearing justice erred in granting Defendants’ motion to dismiss on the grounds that Plaintiffs had not followed the R.I. Gen. Laws 44-5-26 tax appeal process, as section 44-5-26 did not apply in this case; and (2) the appeal process set forth in section 19 of Coventry’s sewer enabling act is the process by which residents of Coventry may appeal sewer assessments or charges levied by Coventry pursuant to its authority under the enabling act. View "Commerce Park Assocs. 1, LLC v. Houle" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree child molestation and five counts of second-degree child molestation. Defendant appealed, arguing, among other things, that the trial justice erred in admitting evidence that Defendant also allegedly molested the complainant's sister. The Supreme Court affirmed, holding (1) the trial justice did not abuse his discretion in admitting evidence of Defendant's other sexual misconduct; (2) the trial justice did not clearly err in denying Defendant's motion for a new trial; and (3) the trial justice correctly denied Defendant's request for new counsel prior to sentencing. View "State v. Mitchell" on Justia Law

Plaintiff sued Defendant for negligence after the vehicles the parties were driving collided in an intersection. A jury found that Plaintiff had not proven, by a fair preponderance of the evidence, that Defendant was negligent. The trial court subsequently granted Plaintiff's motion for a new trial, concluding that, based on the testimony of the independent fact witnesses and other evidence, the court's instructions were not properly understood or applied by the jury. The Supreme Court affirmed the order granting Plaintiff's motion for a new trial, holding that the trial justice had a sufficient basis to find that the jury's verdict did not respond to the evidence, did not overlook or misconceive material facts, and was not clearly wrong in granting Plaintiff's motion for a new trial View "Gomes v. Rosario" on Justia Law

A stone wall demarcated the boundary between Plaintiff's and Defendant's property. After Plaintiff discovered that a large portion of the stone wall had been destroyed and a significant number of trees on his property were missing, Plaintiff sought to recover damages from Defendant for the unauthorized removal of his trees and the theft of portions of the stone wall. After a jury trial, the trial court granted judgments as a matter of law in Defendant's favor. The Supreme Court vacated the judgment of the superior court and remanded for a new trial, holding (1) the trial justice abused her discretion in precluding expert testimony on the subject of historic stone walls, and the exclusion constituted reversible error; and (2) the trial justice committed prejudicial error in granting a judgment as a matter of law in Defendant's favor. View "Morabit v. Hoag" on Justia Law

After a jury trial, Defendant was convicted of kidnapping of a minor and reckless driving. Defendant appealed, arguing that the trial justice erred in admitting testimony about the alleged sexual assault of the kidnapping victim and in denying Defendant's motion for a new trial. The Supreme Court affirmed, holding (1) because the trial justice considered the potential effects of unfair prejudice and confusion of the issues and acted accordingly by issuing limiting instructions to the jury during the trial, the justice did not abuse her discretion in admitting the evidence of the sexual assault; and (2) the trial justice did not overlook or misconceive material evidence and was not otherwise clearly wrong in denying Defendant's motion for a new trial. View "State v. Clay" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, discharging a firearm while committing a crime of violence, and entering a dwelling with the intent to commit a larceny therein. The convictions were affirmed on appeal. Defendant subsequently filed a motion for a new trial, claiming that newly discovered evidence revealed a cooperation agreement between the police and a prominent state's witness in Defendant's murder trial and that the prosecution violated Defendant's due process rights by failing to disclose the full extent of the agreement. The superior court denied the motion. The Supreme Court affirmed, holding (1) the trial court did not err in finding that the alleged newly discovered evidence failed the first prong of the test to be applied for motions based on newly discovered evidence; and (2) Defendant's due process rights were not violated because the state did not fail to disclose information regarding the cooperation agreement. View "State v. Drew" on Justia Law

After a trial, Defendant was convicted of two counts of first-degree child molestation and two counts of first-degree child abuse on a child under the age of five. Defendant was sentenced to concurrent life sentences on the child molestation counts. The Supreme Court affirmed, holding that the trial justice did not err in denying Defendant's motion for a new trial, as that the trial justice conducted the appropriate analysis and reached the same result as the jury after considering the evidence and independently assessing the credibility of the witnesses and the weight of the evidence. View "State v. Baptista" on Justia Law

After John and Anne had been married almost twenty years, John filed a complaint for divorce. Three years later, the parties indicated that they had reached a settlement, which obligated John to provide health insurance for Anne until she reached sixty-five years of age, with a Medicare supplement thereafter. The parties' agreement was read into the record and approved by the trial justice, who ordered it incorporated but not merged into the final divorce decree. However, the parties never executed a written agreement. John later challenged the validity of the marital settlement agreement after Anne moved to enforce the provisions of the agreement respecting John's obligation to pay for health insurance. The family court found that the parties clearly agreed that John was to cover Anne with her health insurance and ordered John to obtain and maintain the health insurance pursuant to the agreement. The Supreme Court affirmed, holding that the agreement was sufficient to form a nonmodifiable marital settlement agreement, and therefore, John was bound by its terms. View "O'Donnell v. O'Donnell" on Justia Law