Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of two counts of second-degree child molestation. Defendant filed a motion for a new trial founded on a claim that he was deprived of pretrial access to certain relevant hospital records and police reports. The trial justice denied the motion after finding that none of the hospital records needed to have been disclosed to trial counsel and that the police reports were not discoverable. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not err in (1) denying Defendant's motion for a new trial; and (2) limiting Defendant's cross-examination of the complaining witness about her refusal to undergo a physical examination. View "State v. Burnham" on Justia Law

In 2003, after completing their respective deferred sentences, Defendants James Briggs and Anna Matthias unsuccessfully moved to expunge the records of their arrests and pleas. Briggs had pled nolo contendere to second-degree robbery, and Matthias had pled nolo contendere to possession of a controlled substance. After the General Assembly amended R.I. Gen. Laws 12-19-19 in 2010, Defendants filed motions to seal their records. The court denied the motions. The Supreme Court affirmed, holding (1) the plain language of section 12-19-19, as amended, does not demonstrate a legislative intent by necessary implication that the General Assembly intended the statute to apply to deferred sentences entered into before the 2010 amendments; and (2) the addition of subsection (c) to section 12-19-19 was a substantive amendment and thus not entitled to retroactive application. View "State v. Briggs" on Justia Law

Defendant was charged by information with threatening a public official with bodily harm as a result of the lawful performance of his official duties. The superior court dismissed the information for lack of probable cause, finding that, based on the contents of the information package, the state would not be able to prove beyond a reasonable doubt that Defendant's statements constituted a threat of bodily harm to a public official in the performance of his public duties. The Supreme Court affirmed, holding that there was no evidence in the record of probable cause to support the charge, and accordingly, the motion justice did not err in dismissing the information. View "State v. Baillargeron" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and three firearms charges. The Supreme Court affirmed Defendant's convictions on all counts. Defendant subsequently filed an application for postconviction relief, alleging ineffective assistance of counsel. The superior court denied Defendant's application. The Supreme Court affirmed, holding that the trial court did not err in concluding (1) trial counsel did not have an actual conflict of interest during Defendant's representation that adversely affected the lawyers' performance; and (2) Defendant's attorneys did not render ineffective assistance in choosing not to pursue a motion to suppress evidence or to mount a third-party perpetrator defense. View "Rivera v. State" on Justia Law

Defendant was a nonprofit conservation corporation that owned beachfront property. Plaintiff filed a complaint seeking the superior court's recognition of its right to traverse Defendant's land to get access to its own property. Plaintiff then amended its complaint to add a claim for easement by prescription. The superior court recognized a prescriptive easement over Defendant's property. The Supreme Court vacated the judgment of the superior court, holding (1) Plaintiff's first complaint sufficiently pleaded a claim for an easement by prescription; but (2) Plaintiff did not establish by clear and convincing evidence that a prescriptive easement existed over Defendants' property. Remanded to permit the parties to supplement the existing record. View "R.I. Mobile Sportfishermen, Inc. v. Nope's Island Conservation Ass'n" on Justia Law

After a jury trial, Defendant was sentenced to life imprisonment for the first-degree murder of his mother. Defendant subsequently filed an application for postconviction relief. The superior court appointed counsel to represent Defendant in connection with his application, but counsel determined that the issues raised in the application were frivolous and without merit and moved to withdraw as attorney of record. After a hearing and a finding that Defendant's arguments were meritless, the hearing justice granted the motion. The hearing justice then denied and dismissed Defendant's application. The Supreme Court affirmed, holding that the hearing justice did not err in (1) granting counsel's motion to withdraw, as all of the procedural requirements of Shatney v. State were followed; and (2) denying Defendant's application after giving Defendant ample opportunity to respond to the proposed dismissal of his application. View "Perez v. State" on Justia Law

Pearl Archambault died while in the care of Haven Health Center of Greenville (Haven Health) after a nurse mistakenly administered a lethal overdose of morphine. The administratrix of her estate, Plaintiff, filed a medical malpractice action against Haven Health. Health Haven subsequently filed for Chapter 11 bankruptcy. Thereafter, Plaintiff amended her complaint to add Columbia Casualty Company, the professional liability insurer of Health Haven, as a defendant and asserted two counts against Columbia directly based on R.I. Gen. Laws 27-7-2.4, which permits an injured party to proceed against an insurer when the insured has filed for bankruptcy. The superior court entered default judgment against Haven Health. The court then granted summary judgment in favor of Columbia. The Supreme Court reversed and remanded with instructions to enter judgment against Columbia, holding that the superior court erred in interpreting Rhode Island law and that the insurance contract between Columbia and Health Haven should be construed in Plaintiff's favor. View "Peloquin v. Haven Health Ctr. of Greenville, LLC" on Justia Law

Dean Pepper, the owner and sole shareholder of D.F. Pepper Construction (DFP) was driving one of his trucks home in the early winter morning. An icy road caused the truck to slide into Pepper's house and crash through the foundation and west wall. The house was later condemned and demolished as a result of the damage. The house was insured by Nationwide Casualty Insurance Company. Nationwide paid the loss. As subrogee of Pepper, Nationwide then sued DFP, the registered owner of the truck, alleging vicarious liability for the negligence of its employee, Pepper. The superior court issued judgment in favor of Nationwide, finding that Pepper had been negligent and that the antisubrogation rule did not apply in this case. The Supreme Court affirmed, holding that the trial court did not err in its judgment. View "Nationwide Prop. & Cas. Ins. Co. v. D.F. Pepper Constr., Inc." on Justia Law

DWS Properties (DWS) owned rental property. The sole member of DWS was Dustin Shore. After a pipe burst at the property causing substantial damage, Shore executed contracts with Performance Adjusting Public Insurance Adjusters (Performance) and Multi-State Restoration (Multi-State), in which Performance agreed to provide public adjusting service relative to the loss, and Multi-State agreed to perform emergency clean-up work at the property. Performance and Multi-State (Plaintiffs) were never paid for the services they provided, and after Shore filed for personal bankruptcy, Shore's debts to Plaintiffs were discharged. Plaintiffs subsequently filed suit against DWS, seeking damages for book account, breach of contract, quasi-contract, and unjust enrichment. DWS filed a motion to dismiss, which the hearing justice converted into a motion for summary judgment and granted, reasoning that Shore had signed the contracts in an individual capacity without making any reference to DWS. The Supreme Court vacated the judgment of the superior court and remanded, holding (1) summary judgment was inappropriate on Plaintiffs' contract claims; and (2) the fact that DWS was not explicitly named on the contracts did not entitle it to judgment as a matter of law on Plaintiffs' equitable claims. View "Multi-State Restoration, Inc. v. DWS Props., LLC" on Justia Law

Defendant entered pleas of nolo contendere to three counts of second-degree child molestation, and the hearing justice accepted Defendant's plea. Five months later, Defendant filed an application for postconviction relief, claiming that his conviction should be vacated because his plea was involuntary and because he had been denied his right to the effective assistance of counsel. The superior court dismissed Defendant's application. The Supreme Court affirmed, holding (1) Defendant voluntarily pleaded to the charges; (2) Defendant's attorney did not render ineffective assistance in pressuring him to plead to the charges or in failing to advise Defendant to inform the court that he had ingested prescription medication during the plea hearing; and (3) the hearing justice did not err in failing to draw an adverse inference against the state based on its failure to call upon Defendant's plea attorney to testify at the postconviction-relief hearing. View "Jolly v. Wall" on Justia Law