Justia Rhode Island Supreme Court Opinion Summaries

After Shelley Tyre died, her parents brought a wrongful-death action against Shelley's husband, David Swain, alleging that he caused Shelley's wrongful death, that he was a slayer pursuant to R.I. Gen. Laws 33-1.1-1(3), and he should be subject to civil liability for a criminal act. After a jury trial, the court found in favor of Shelley's parents on all three counts. The probate judge later issued an order declaring that neither Swain, nor his heirs at law, should receive directly or indirectly from Shelley's estate pursuant to the Rhode Island Slayer's Act. Accordingly, Plaintiffs, David's children and Shelley's stepchildren, were precluded from inhering under Shelley's will as contingent beneficiaries because this inheritance would confer a benefit on their father. The Supreme Court affirmed, holding that Plaintiffs' taking under Shelley's will would unquestionably confer a benefit upon David, in direct contravention of the Slayer's Act. View "Swain v. Estate of Tyre" on Justia Law

Plaintiffs in this case included fifteen minor children and their parents who participated in the family court's truancy court diversion calendar program. The diversion program allowed family court magistrates to conduct court sessions at public schools where truancy had become an issue. Plaintiffs brought an action against the judicial officials who were sitting in the truancy court, family court administrators, and five municipalities. Plaintiffs requested that the superior court declare the previous procedures in the truancy court to be unconstitutional and enjoin the family court from enforcing the prior procedures. The superior court denied Defendants' motions to dismiss under Sup. Ct. R. Civ. P. 12(b)(1). The Supreme Court quashed the superior court's order denying Defendants' motions to dismiss, holding that Plaintiffs' claims were moot, as (1) Plaintiffs' constitutional challenges were obviated by an administrative order that reformed the truancy program and by existing law; and (2) there were no ongoing truancy petitions that continued to be affected by the earlier court procedures. View "Boyer v. Bedrosian" on Justia Law

Defendant was convicted of violating his probation. The superior court executed thirty months of Defendant's previously imposed suspended sentence. The Supreme Court affirmed the judgment of the superior court, holding (1) Defendant waived his argument for appeal that the hearing justice properly refused to admit a letter written and sent to him by the State's complaining witness; (2) the hearing justice did not abuse its discretion in limiting testimony concerning past arguments between Defendant and the complaining witness about the complaining witness's drug use and whether the complaining witness had bought him drugs when he was in a drug-treatment program; and (3) the hearing justice did not act arbitrarily and capriciously in finding a violation. View "State v. Ford" on Justia Law

Pursuant to a divorce decree, Plaintiff was awarded sole custody of her and Defendant's daughter, as well as all personal property in her possession, with a few exceptions, including a pair of diamond earrings. Later, Plaintiff filed a motion for the return of missing property and a federal question motion alleging a constitutional valuation due to a court clerk's failure to docket his earlier motion for an evaluation of his daughter. At a hearing, Plaintiff turned over the diamond earrings that were purportedly awarded to Defendant in the divorce decree, and the hearing justice then dismissed the two motions. Defendant subsequently asserted that Plaintiff had given him the wrong earrings. A hearing justice approved the proposed order dismissing Defendant's motion for return of missing property with prejudice. The Supreme Court affirmed the order of the family court, holding (1) the hearing justice properly denied Defendant's federal question motion, as Defendant did not appeal the entry of final judgment in his divorce and, thus, the Court lacked jurisdiction to hear custody and visitation issues in this case; and (2) the hearing justice did not err in dismissing Defendant's motion for the return of personal property with prejudice. View "Richards v. Fiore" on Justia Law

Defendant was convicted of first-degree murder. The Supreme Court affirmed the conviction. Nearly a decade later, Defendant filed a pro se application for postconviction relief, claiming six allegations of error. The trial justice dismissed five out of the six allegations raised in the application as barred by principles of res judicata. A court-appointed attorney subsequently made an independent evaluation to determine whether Defendant's remaining claim of ineffective assistance of counsel had merit. Appointed counsel concluded that none of Defendant's arguments had merit. A trial justice then informed Defendant that his only allegation of ineffective assistance of counsel could proceed to a hearing and that he had no right to be represented by an attorney. After a hearing in which Defendant proceeded pro se, the trial justice granted the State's motion to dismiss. The Supreme Court vacated the judgment and remanded, holding (1) the trial justice erred in summarily dismissing five of Defendant's claims without first providing him with appointed counsel and a meaningful opportunity to respond; and (2) the trial justice's appointment of an "objective attorney" to make an "independent evaluation" of the merits of Defendant's claim of ineffective assistance of counsel violated R.I. Gen. Laws 10-9.1.5. View "Campbell v. State" on Justia Law

Defendant was convicted of one count of first degree child molestation and two counts of second degree of child molestation. Defendant was the great-uncle of the complaining witness. On appeal, Defendant argued that the trial justice erred in failing to grant his motion for a new trial due to the lack of credibility of the witnesses and the inconsistent evidence concerning the alleged molestations. The Supreme Court affirmed, holding that the trial justice did not clearly err or misconceive evidence in denying Defendant's motion for a new trial, as the trial justice completed each of the analytical steps called for when a trial justice is presented with a motion for a new trial. View "State v. Gonzalez" on Justia Law

Defendant was convicted of aiding and abetting murder and conspiracy to commit robbery. The Supreme Court affirmed on direct appeal. Defendant subsequently filed an application for postconviction relief, setting forth five allegations of error, including the allegation that counsel's failure to seek dismissal of the indictment on speedy trial grounds amounted to ineffective assistance of counsel. The trial justice denied the application. The Supreme Court affirmed, holding that the trial justice's denial of Defendant's allegation of ineffective assistance of counsel was correct, as Defendant's speedy-trial contention ultimately would have proven unsuccessful, and Defendant could not show that the result of the proceeding against him would have been different. View "Bido v. State" on Justia Law

Plaintiff sent a notice of claim to Defendants, a town and its finance director, for injuries she sustained on the town's sidewalk. Defendants filed a motion for summary judgment, arguing that the complaint should be dismissed because the notice of the place of injury was insufficient as a matter of law because Plaintiff misidentified the location where her injury occurred and her descriptions of the location were inconsistent. The trial justice granted Defendants' motion for summary judgment. The Supreme Court affirmed, holding that the relevant statute clearly and unambiguously requires that the notice of claim must be specific, and therefore, the notice in this case was insufficient. View "Carbone v. Ward" on Justia Law

Two enforcement officers of the Rhode Island Department of Environmental Management (DEM) boarded a boat owned by Daniel Barlow when Barlow was not on board and allegedly discovered the amount of summer flounder Barlow caught that day was more than was permitted under the applicable regulations. A notice of violation followed. In the ensuing litigation, the DEM found Barlow ineligible to participate in its 2010 Summer Flounder Sector Allocation Pilot Program because of a previous consent agreement he had entered into with the department. The agreement reflected a settlement of the allegation that Barlow violated a state marine fisheries regulation for catch limits. The Administrative Adjudication Division of DEM reversed, finding the consent agreement was not an administrative penalty because it absolved Barlow of all liability arising from the alleged violation. The superior court reversed. The Supreme Court quashed the decision of the superior court and found in favor of Barlow, holding that DEM wrongly used the consent agreement as a reason to bar him from the program. View "State Dep't of Envtl. Mgmt. v. Admin. Adjudication Div." on Justia Law

Plaintiff, who was employed as a school bus driver, broadcasted that the bus she was driving, which was full of elementary-school children, had been struck by gunfire and that panic had spread among the children. Displeased with the manner in which Plaintiff handled the situation, the Town of Johnson school department requested that Plaintiff no longer be assigned to transport Johnson students. Eventually, Plaintiff left her employment. Plaintiff subsequently filed suit for wrongful termination against members of the Johnson public schools (Defendants), alleging that Defendants wrongfully requested that Plaintiff be terminated from her employment. In response to the trial justice's remarks, Plaintiff moved to amend her complaint to include a claim of tortious interference, which the trial justice denied. Thereafter, the superior court granted summary judgment against Plaintiff. The Supreme Court vacated the judgment of the superior court, holding that the court abused its discretion in denying Plaintiff's motion to amend her complaint without specific findings. Remanded. View "Lomastro v. Iacovelli" on Justia Law