Justia Rhode Island Supreme Court Opinion Summaries

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The Supreme Court vacated the judgment of the superior court granting Verizon New England Inc.'s motion to dismiss this complaint related to a billing dispute over a particular telephone service contract, holding that the hearing justice erred in granting Defendant's motion to dismiss, which had been converted sub silentio to a motion for summary judgment.Plaintiff filed a complaint against Verizon alleging false representation and breach of contract stemming from a billing dispute. Verizon filed a motion to dismiss under Sup. Ct. R. Civ. P. 12(b)(6). The hearing justice dismissed Plaintiff's complaint in its entirety with prejudice. The Supreme Court vacated the judgment below, holding that that issues of genuine material fact existed precluding summary judgment. View "Resmini v. Verizon New England Inc." on Justia Law

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The Supreme Court affirmed the order of the superior court denying Defendant's motion to correct an illegal sentence, holding that there was no error on the part of the trial justice in denying Defendant's motion to correct his sentence.After a jury trial, Defendant was convicted of two counts of assault with a dangerous weapon in a dwelling house. As part of his sentence and as relevant to this appeal, Defendant received a ten-year nonparolable sentence enhancement as a habitual offender to be served consecutively to his first sentence. Defendant later filed a motion to correct an illegal sentence, arguing that his habitual offender sentence enhancement was illegal. The trial justice denied the motion. The Court of Appeals affirmed, holding that the trial justice correctly complied with the habitual offender statute. View "State v. Davis" on Justia Law

Posted in: Criminal Law
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The Supreme Court vacated the judgment of Supreme Court in favor of Plaintiff Wilmington Savings Fund Society, FSB in this case involving a dispute over payments due under a promissory note relating to Defendants' mortgage, holding that summary judgment was improperly granted under the terms of this case.Plaintiff's predecessor filed a complaint against Defendants alleging breach of contract. The hearing justice granted summary judgment in favor of Plaintiff. Defendants appealed, arguing that the issue of whether Plaintiff complied with the note's notice provisions was a question of material fact precluding summary judgment. The Supreme Court vacated the judgment below, holding that Plaintiff's failure to send the notice of default to the property address referred to in the note was not in accordance with the terms of the note, and therefore, summary judgment should not have been granted. View "Wilmington Savings Fund Society, FSB v. Cavalloro" on Justia Law

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In this dispute arising from an ill-fated attorney-client relationship the Supreme Court affirmed the judgment of the superior court grantinf Plaintiff's motion for summary judgment, holding that there was no error in the proceedings below.Plaintiff filed a complaint alleging breach of contract and seeking to recover almost $13,000 for unpaid services provided to Defendant and claiming that she was entitled to statutory interest, attorneys' fees, and costs of suit. The hearing justice granted Plaintiff's unopposed motion for summary judgment. The Supreme Court affirmed, holding that there was no disputed issue of material fact and that Defendant was liable for the outstanding balance due as payment for Plaintiff's services. View "Oliveira v. Levesque" on Justia Law

Posted in: Contracts
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The Supreme Court vacated the judgment of the superior court in favor of Defendant, in his capacity as the finance director/treasurer for the Town of Smithfield, in this action challenging the calculation of a former employee's retirement benefits, holding that the court erred in concluding that Plaintiff had failed to exhaust his administrative remedies.Armand Beaudry worked as a firefighter for the Town for several years before he was placed on disability retirement benefits. The retirement benefits were governed by a pension system that constituted "an amalgamation of various documents." The case arose from a dispute over the calculation of Beaudry's benefits. Beaudry filed a complaint challenging the amount. The trial court granted the Town's motion for summary judgment based on failure to exhaust administrative remedies. The Supreme Court vacated the judgment, holding that the hearing justice erred by finding that a challenged amendment to the plan was enforceable at the time of Beaudry's retirement, thus creating an administrative remedy that Beaudry failed to exhaust. View "Beaudry v. Rossi" on Justia Law

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The Supreme Court affirmed the order of the superior court denying Petitioner's petition for a writ of mandamus and dismissing his complaint pursuant to Sup. Ct. R. Civ. P. 12(b)(1) and 12(b)(6), holding that the superior court did not err.Plaintiff, a former employee of the City of East Providence, attempted to rescind an agreement he made with the City regarding, among other things, his retirement benefits and the issuance of a corrected W-2 to reflect his injured-on-duty status. The trial judge entered judgment for the City. Plaintiff then filed a complaint and petition for a writ of mandamus against his union asking the superior court to abrogate agreement regarding the period of his injured-on-duty status. The trial court granted Defendants' motion to dismiss. The Supreme Court affirmed, holding (1) several of Plaintiff's arguments were waived; and (2) this case was barred by res judicata. View "Jenkins v. City of East Providence" on Justia Law

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The Supreme Court affirmed the decree of the family court terminating Father's parental rights to his daughter, R.M., holding that Father was not entitled to relief as to his arguments on appeal.The Department of Children, Youth, and Families (DCYF) filed a petition to terminate the parental rights of Father based on his incarceration and the child's placement the care of DCYF for more than twelve months. The trial justice ultimately determined that DCYF had met its burden of proof for the termination of parental rights petition by clear and convincing evidence and that termination of Father's parental rights was in the best interests of the child. The Supreme Court affirmed, holding that the trial justice did not err in (1) its finding as to parental unfitness; (2) finding that DCYF made reasonable efforts to "encourage and strengthen the parental relationship"; and (3) determining that it was in R.M.'s best interests for Father's parental rights to be terminated. View "In re R.M." on Justia Law

Posted in: Family Law
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The Supreme Court quashed the order of the superior court granting Defendant's motion for a protective order limiting the deposition testimony of Plaintiff's expert witness to causation opinions and prohibiting Plaintiff from further supplementing the expert witness's disclosure to include other opinions, holding that the trial justice erred.Plaintiff brought this medical malpractice action alleging negligence. The trial justice later granted Defendant's motion for a protective order seeking to preclude the expert witness from offering opinions regarding the standard of care and prohibited Plaintiff from supplementing the witness's disclosure to include opinions on topics outside of causation, including standard of care. The Supreme Court quashed the decision below, holding that the trial justice abused her discretion in granting Defendant's motion. View "Vecchio v. Women & Infants Hospital" on Justia Law

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The Supreme Court affirmed the judgment of the superior court declaring Defendant to be in violation of the terms and conditions of his probation, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that there was a lack of sufficient evidence to support a finding that he had violated his probation and, alternatively, that the trial justice imposed an excessive sentence for the violation. The Supreme Court affirmed, holding that the trial justice (1) did not act arbitrarily or capriciously in concluding that Defendant had violated his probation; and (2) did not abuse his discretion sentencing Defendant to thirty-six months of his suspended sentences, two months to remain suspended. View "State v. Perkins" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court convicting Defendant of felony assault resulting in serious bodily injury and sentencing him to a term of twenty years at the Adult Correctional Institutions, holding that any error was harmless.On appeal, Defendant argued that the trial justice erred in admitting evidence that he struck an unrelated person in an unrelated event earlier on the evening in question, in violation of R.I. R. Evid. 404(b) and 403. The Supreme Court affirmed the conviction, holding (1) the admission of the challenged evidence was an abuse of discretion; but (2) the error did not contribute to the jury's evaluation of the evidence and Defendant's conviction and amounted to harmless error. View "State v. DeCosta" on Justia Law

Posted in: Criminal Law