Justia Rhode Island Supreme Court Opinion Summaries

Bowen's Wharf was a tourist destination including a marina and a variety of retailers, restaurants, and art galleries. In this appeal, the Supreme Court was called upon to decide a question that would clarify the rights and obligations of two adjacent landholders whose combined property comprised the entirety of Bowen's Wharf. The question presented for review was whether the trial justice erred in finding that a right of first refusal granted to Defendant, Bowen's Wharf Company, Inc., by Plaintiff, Ronald Fatulli, in 1969 had expired by expiration of law. The trial justice found the parties' right of first refusal agreement expired in 1979, and accordingly, Plaintiff was not obligated to offer a parcel of the property, a wharf, and a business to Defendant in the event of a bona fide third party's offer. The Supreme Court affirmed, holding (1) the trial court did not err in finding that, on these facts, a wharf or dock may properly be characterized as real property; and (2) Defendant's right of first refusal expired by operation of R.I. Gen. Laws 34-4-26, which governs the expiration of recorded rights affecting real estate. View "Fatulli v. Bowen's Wharf Co." on Justia Law

Defendant appealed from a superior court judgment of conviction declaring him to be in violation of his probation and executing four years of his previously imposed suspended sentence. On appeal, Defendant argued there was no reliable evidence for the hearing justice to find he violated the terms of his probation and therefore, the hearing justice acted arbitrarily and capriciously in finding a violation. The Supreme Court affirmed the judgment of the superior court, holding that the hearing justice was well within her discretion in concluding that Defendant violated the terms of his probation by not keeping the peace or being of good behavior. View "State v. Bellem " on Justia Law

An automobile registered to Defendant struck a parked car that was registered to Plaintiff. Plaintiff subsequently filed a complaint against Defendant seeking damages pursuant to R.I. Gen. Laws 31-33-6 and 31-33-7. Section 31-33-6 provided that a vehicle owner may be liable for the acts of another person who operates the owner's car with the consent of the owner. Section 31-337 provided that the absence of consent shall be an affirmative defense and proved by the defendant. Defendant raised such an affirmative defense in her answer to Plaintiff's complaint. The trial court granted Defendant's motion for summary judgment, ruling that Defendant's car was stolen, and Defendant did not give permission for anyone to drive the vehicle. Plaintiff appealed, contending that inconsistencies in the evidence created genuine issues of material fact as to whether Defendant gave the unidentified driver consent to use her car the day of the collision. The Supreme Court reversed, holding that genuine issues of material fact regarding the issue of consent precluded summary judgment in this case. View "Pichardo v. Stevens" on Justia Law

Appellant was convicted of first-degree murder, assault with intent to murder, and assault with a dangerous weapon. Appellant subsequently filed an application for postconviction relief, which the superior court denied. On appeal, Appellant contended (1) his postconviction relief application should have been granted based on a violation of his right to due process, and (2) he was prejudiced by the ineffective assistance of his trial counsel because his counsel failed to object to what Appellant maintained was improper witness vouching and because his trial counsel failed to object to a first-degree murder instruction that the trial justice imparted to the jury. The Supreme Court affirmed the denial of Appellant's application for postconviction relief, holding (1) Appellant's postconviction challenge was barred by the doctrine of res judicata, and Appellant's conviction was proper; and (2) trial counsel did not render ineffective assistance. View "Jaiman v. State" on Justia Law

Defendant appealed from a judgment of conviction on two counts of assault with a dangerous weapon and one count of discharging a firearm while committing a crime of violence. Defendant argued on appeal that the trial justice erred when he (1) admitted into evidence a prejudicial hearsay statement as an excited utterance; and (2) admitted a statement as lay-witness opinion testimony. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not abuse his discretion when he (1) admitted into evidence the hearsay statement as an excited utterance; and (2) allowed a lay witness to testify as to what he perceived at the time of the alleged shooting. View "State v. Tep" on Justia Law

After a jury trial, Defendant was found guilty of burglary, robbery in the first degree, and assault on a person over the age of sixty. The complainant, who was seventy-one years old at the time of trial, had suffered a stroke and couldn't remember "a lot of things" and also took prescription medication daily. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not err in (1) refusing to explicitly instruct the jury that, in assessing credibility, it could consider a witness's ability to observe and recall; (2) refusing to instruct the jury that a history of drug abuse may weaken the credibility of a testifying witness; and (3) denying Defendant's motion for a new trial, as "any reasonable jury would found Defendant guilty beyond a reasonable doubt." View "State v. Ricci" on Justia Law

Under the terms of a collective-bargaining agreement, the City of Newport provided health insurance benefits to its retired firefighters. After the City decided to modify those benefits, Local 1080, International Association of Firefighters, ALF-CIO (Union) filed grievances and sought arbitration. The City responded by seeking relief in the superior court to determine the arbitrability of disputes over changes to these benefits. The superior court determined that this dispute was not arbitrable. The Union disagreed and petitioned the Supreme Court for a writ of certiorari. The Court affirmed the judgment of the superior court, holding that the parties did not intend to arbitrate disputes regarding retiree healthcare, and therefore, such disputes must be resolved, if at all, judicially rather than through arbitration. View "City of Newport v. Local 1080, Int'l Ass'n of Firefighters, AFL-CIO" on Justia Law

Defendant appealed from a superior court judgment of conviction for first-degree murder and three related crimes. On appeal, Defendant argued that the trial justice erred in denying his pretrial motions to suppress evidence and that the trial justice improperly denied his motions for a new trial and for a judgment of acquittal. The Supreme Court affirmed the judgment of the superior court, holding (1) the trial justice did not err in denying Defendant's motions to suppress; and (2) because the evidence was sufficient to support Defendant's convictions, the trial justice did not err when it denied Defendant's motions for a judgment of acquittal and for a new trial. View "State v. Musterd" on Justia Law

The family court terminated the parental rights of Father and Mother (collectively, Respondents) to their daughter, Amiah P., after finding that both parents presented troubling histories involving imprisonment and drugs, that both parents had been incarcerated and Father was currently incarcerated, and that Amiah had been in foster care for nearly two years and had bonded with her foster family. The Supreme Court affirmed the family court's decree, holding that there was ample evidence to support the trial justice's finding that the Rhode Island Department of Children, Youth and Families proved by clear and convincing evidence that Respondents were unfit parents and that the termination of their parental rights was in Amiah's best interests. View "In re Amiah P." on Justia Law

Defendant appealed from a conviction of two felony counts of assault with a dangerous weapon and one count of discharging a firearm while committing a crime of violence. On appeal, Defendant argued (1) his statement to police should have been suppressed as the tainted fruit of an unlawful arrest; and (2) the trial justice deprived him of his right to confrontation by prohibiting defense counsel from cross-examining two police witnesses concerning his statements to police. The Supreme Court affirmed the judgment of conviction, holding, (1) the issue concerning the trial justice's denial of the motion to suppress was not a proper subject on appeal because at no point during Defendant's trial did the state introduce into evidence the statement he gave to the police, and moreover, Defendant's contention was without merit; and (2) Defendant did not properly preserve for the Court's review any challenge to the trial justice's limitations on his cross-examination, but nonetheless, the contention lacked merit. View "State v. Chum" on Justia Law