Justia Rhode Island Supreme Court Opinion Summaries

Dr. James Gallo treated Plaintiff in 2003 and 2004. Thereafter, Plaintiff filed a complaint against Gallo and West Bay Psychiatry Associations, including claims for slander for remarks uttered in two separate proceedings. The first alleged slander occurred when Gallo's deposition was taken in connection with Plaintiff's case before the Workers' Compensation Court (WCC). The second alleged slander occurred when Gallo testified before the Rhode Island Department of Education (RIDE) regarding Plaintiff's alleged wrongful termination from her teaching position. The superior court entered summary judgment for Defendants on Plaintiff's slander claims. The Supreme Court affirmed, holding that the motion justice did not err in finding (1) Plaintiff's claim for slander based on Gallo's WCC deposition testimony was time-barred; and (2) Plaintiff's claim for slander based on Gallo's RIDE testimony was immunized from defamation claims by the testimonial privilege because it qualified as having occurred in a judicial proceeding. View "Francis v. Gallo" on Justia Law

A motor vehicle collision involving Plaintiff and Defendant occurred when Plaintiff was riding his motorcycle and Defendant was driving a car belonging to his girlfriend. Plaintiff filed a complaint against Defendant and his girlfriend, alleging that Defendant had been negligently operating the car at the time of the collision. Defendants filed a motion for summary judgment, contending that the incident was in actuality a rear-end collision caused by Plaintiff. The superior court granted Defendants' motion, concluding that Plaintiff had struck the car from the rear. The Supreme Court reversed, holding that there was sufficient conflicting evidence on the issue of negligence for this case to be submitted to a fact-finder. View "DeMaio v. Ciccone" on Justia Law

Plaintiff was a Massachusetts corporation when it entered into a contract with Defendants. The contract was to be performed entirely in Rhode Island. Defendants subsequently commenced a civil action against Plaintiff. At the time, Plaintiff had a certificate of authority from the secretary of state, but after Plaintiff filed this action, the corporation's certificate of authority was revoked. The superior court granted summary judgment in favor of Defendants, determining that Plaintiff did not have a certificate of authority to transact business in Rhode Island, and therefore, it lacked the capacity to sue in the state. The Supreme Court reversed, holding that a certificate was not required in this instance, but Plaintiff must obtain a certificate before proceeding to final judgment. View "Custom Metals Sys., Ltd. v. Tocci Building Corp." on Justia Law

Defendant entered an Alford plea to two counts of second-degree child molestation. Seventeen years later, Defendant filed an application for postconviction relief, arguing that there was not sufficient evidence for the trial justice to support a conclusion that Defendant understood both the nature of the charges and the consequence of the plea, and thus, the plea was not made voluntarily and intelligently. The superior court denied the application. The Supreme Court affirmed, holding that there was no basis to vacate Defendant's plea, as Defendant's plea was voluntary, intelligent, and knowing, and Defendant was well aware of the nature of the charges against him at the time he pleaded to them. View "Camacho v. State" on Justia Law

Jared Crook was driving a Cadillac leased for him by his father, Calvin Crook, when he collided with Jessica Ahlquist's vehicle. Ahlquist sustained severe personal injuries as a result of the accident. The Cadillac was insured by Calvin through a policy issued by Allstate Insurance Company. Allstate paid the policy limits, and Ahlquist sought to recover additional compensation through another Allstate policy issued to Cheryl, Calvin's former wife. The policy was issued for Cheryl's vehicle. Allstate filed a declaratory judgment action arguing that Cheryl's insurance policy did not apply to the accident. The trial justice granted summary judgment in Allstate's favor. Ahlquist appealed, contending that the trial justice erred in granting summary judgment because Calvin, who was a named driver under Cheryl's insurance policy, provided the Cadillac to Jared. Ahlquist also argued that there was an ambiguity as to whether the policy covered the accident. The Supreme Court affirmed, holding that the trial court did not err in its judgment. View "Allstate Ins. Co. v. Ahlquist" on Justia Law

In 1992, Defendant pleaded nolo contendere several charges, including first- and second-degree child molestation. Defendant was sentenced to thirty years on each of the molestation counts, with fifteen years to serve, fifteen years suspended, with probation. Defendant was later convicted of residential burglary and adjudicated a probation violator in 2004. After a probation-revocation hearing, the superior court stayed the execution of ten years of Defendant's previously suspended sentence. In 2009, Defendant admitted to a probation violation. In 2010, Defendant filed a motion to correct the 2004 sentence, arguing that the trial justice was without authority to impose a stayed sentence. The trial court granted in part Defendant's motion and vacated the 2004 sentence. The trial justice then resentenced Defendant. Defendant appealed, arguing that the 2004 was no longer a viable sentence, such that Defendant was improperly adjudged to be a probation violator in 2009, and that the trial justice impermissibly resentenced him. The Supreme Court affirmed, holding (1) the trial justice's error in staying the execution of the ten years remaining on the previously suspended sentence did not vitiate that portion of the sentence that the original sentencing justice had imposed; and (2) the trial justice correctly resentenced Defendant. View "State v. Roberts" on Justia Law

Plaintiff filed a civil action against Sportsman's Inn, Inc., a hotel and lounge, and DLM, Inc., the corporation that leased the premises to the hotel, alleging that he was shot as a result of the failure of Defendants to provide adequate security at the business. Several months later, Plaintiff learned that the property where the hotel was located was for sale, and moved for a preliminary injunction. The trial justice granted Plaintiff's motion to enjoin the sale of the property, concluding that Plaintiff had established a likelihood of success that the corporate formalities should be disregarded and that Sportsman's Inn had breached its duty of reasonable care to him. Defendants appealed, contending that the trial justice erred in finding Plaintiff had demonstrated there was a reasonable likelihood of success on the merits of the negligence claim and that the corporate veil should be pierced. The Supreme Court vacated the superior court's order granting a preliminary injunction, holding that Plaintiff did not establish a reasonable likelihood of success on the merits of his underlying negligence claim and that a "piercing of the corporate veil" analysis was unnecessary at this stage of the litigation. View "Vasquez v. Sportsman's Inn, Inc." on Justia Law

A general contractor (Carlisle) for a construction project contracted with Plaintiff to perform carpentry work for the project. A bond was issued for the project. Carlisle was the principal on the bond, and International Fidelity Insurance Company (IFIC) was the surety. Plaintiff later filed suit against Carlisle and IFIC seeking to recover payment for the work it performed. The arbitrator issued two amended awards. Plaintiff moved the superior court to confirm the second amended awarded concerning Carlisle's liability and to modify it as to IFIC. The trial justice remanded the matter back to the arbitrator for a determination as to IFIC's liability. The arbitrator on remand found that both Carlisle and IFIC were liable to Plaintiff for $43,543. The trial justice confirmed the post-remand arbitration award. The Supreme Court affirmed but on different grounds, holding (1) the second amended award should have been vacated under R.I. Stat. 37-16-18(2), and the trial justice was authorized, under section 37-16-19, to remand the case to the same arbitrator for a hearing; and (2) because the remand in this case accomplished the same result that could have been accomplished under section 37-16-18 and 37-16-19, the judgment was affirmed. View "Drago Custom Interiors, LLC v. Carlisle Bldg. Sys., Inc." on Justia Law

After a jury trial, Defendant was convicted of three counts of first-degree child molestation and three counts of second-degree child molestation. Defendant appealed, arguing that the trial justice's denial of his motion for a new trial was clearly erroneous because the jury's verdict was against the weight of the evidence and failed to do substantial justice. Specifically, Defendant argued that the testimony of the complaining witness lacked credibility. The Supreme Court affirmed, holding (1) the trial justice performed an exhaustive review of the testimony presented at trial and thoughtfully evaluated the evidence and credibility of the witnesses; and (2) the trial justice's findings and conclusions in denying Defendant's motion for a new trial were well within his discretion. View "State v. LaPierre" on Justia Law

Defendant was convicted of possession of cocaine with the intent to deliver and possession of cocaine in an amount between one ounce and one kilogram. In his appeal, Defendant challenged the denial of his motion to suppress evidence seized from his home, arguing that the affidavit underlying the warrant did not provide the requisite probable cause to support a search of his residence. The Supreme Court affirmed, holding (1) the totality of the circumstances presented within the affidavit was sufficient to enable the magistrate to reasonably infer that illegal contraband would be found in Defendant's residence; and (2) the trial justice did not err in determining that the confidential informant's tip was properly corroborated or that this corroborated tip, combined with Defendant's recent sale of cocaine in a controlled buy, satisfied the probable cause requirement to support the warrant authorizing the search of Defendant's residence. View "State v. Cosme" on Justia Law