Justia Rhode Island Supreme Court Opinion Summaries

Plaintiffs brought suit against Defendant, the Cranston School Department, seeking grievance arbitration of adverse actions taken against them as to their respective coaching positions at Cranston West High School. Plaintiffs, both of whom were teachers at Cranston West, separately filed grievances against Defendant in accordance with the collective bargaining agreement (CBA) that was in place between the Cranston Teacher's Alliance and the school department. Defendant responded that the CBA did not apply to Plaintiffs in their capacity as coaches, and it refused to submit to arbitration. Plaintiffs filed suit, seeking a declaratory judgment that they were entitled to binding arbitration as guaranteed by the CBA. The superior court ruled in favor of Defendant, determining that Plaintiffs, in their capacity as coaches, were not entitled to avail themselves of the CBA's grievance procedures. The Supreme Court affirmed, holding (1) the trial justice was correct in determining that Plaintiffs' coaching positions were contractually distinct from their teaching positions and did not constitute professional employment; and (2) Plaintiffs in their coaching capacities had no right to pursue relief based on the rights bargained for by the alliance on behalf of its teacher-members and as contained in the CBA. View "Sacco v. Cranston Sch. Dep't" on Justia Law

Plaintiff Mutual Development Corporation appealed a Superior Court's grant of summary judgment in favor of defendants Ward Fisher & Company, LLP (Ward Fisher) and WF Realty & Investment, LLC (WF Realty). On appeal, plaintiff contended that the hearing justice improperly interpreted and applied subsection 6 of G.L. 1956 sec. 9-1-4 (the Statute of Frauds) in deciding that that subsection could properly be invoked with respect to an alleged oral finder's fee agreement between plaintiff and the defendants, thereby barring recovery by plaintiff. The Supreme Court requested the parties address" (1) "the issue of whether there is a distinction between a finder and a broker with respect to real estate transactions, and, if so whether the language of the statute of frauds, G.L. 1956 sec. [9-1-4], encompasses a finder as well as a broker;" and (2) the issue of "[w]hether the statute of frauds applies equally to percentage-based commissions and flat-sum commissions, or solely to percentage-based commissions or fees." After review, the Supreme Court affirmed the judgment of the Superior Court. View "Mutual Development Corporation v. Ward Fisher & Company, LLP et al." on Justia Law

After a consolidated trial, a Providence County Superior Court jury found Defendant John Kluth guilty of thirty counts of obtaining money by false pretenses. Thereafter, the trial justice sentenced Defendant to a total of thirty-five years, with sixteen years to serve at the Adult Correctional Institutions and the remainder suspended, with probation. On appeal, he contended: (1) that the then presiding justice of the Superior Court exceeded his authority in granting the prosecutor's request to change venue; (2) that the charges filed against him were improperly joined as a matter of law, in view of the provisions of Rule 8(a) of the Superior Court Rules of Criminal Procedure; and (3) that, even if the charges had been properly joined, the trial justice's failure to sever the cases infringed upon his right to a fair trial. Upon review, the Supreme Court affirmed the judgments of the Superior Court. View "Rhode Island v. Kluth" on Justia Law

Defendant Juan Diaz appealed his conviction on second-degree murder and one count of using a firearm while committing a crime of violence. On appeal, Defendant argued that the trial justice erred in failing to grant his motion for a judgment of acquittal on the second-degree murder charge because the state failed to provide legally sufficient evidence for a jury to find that he acted with malice in connection with the death of the victim. Furthermore, Defendant argued that the trial justice erred in omitting the phrase "criminal negligence" from his instruction to the jury concerning involuntary manslaughter and instead used "confusing language," which made it difficult for the jury to distinguish the crime of involuntary manslaughter from the crime of murder in the second degree. Upon review, the Supreme Court found that "in order to have properly weighed the charges brought against the defendant, it was crucially important that the jury in this case receive an involuntary manslaughter instruction that included the concept of criminal negligence, thereby creating a distinct and separate charge from that which was given for murder in the second degree." The Court held that the trial justice erred in declining to include that concept in his instruction on involuntary manslaughter. Accordingly, the Court vacated Defendant's judgment of conviction. View "Rhode Island v. Diaz" on Justia Law

Defendant Julie Robat appealed her conviction on one count of second-degree murder. The victim was Defendant's newborn daughter. On appeal, Defendant contended that the trial justice erred in failing to grant her motion for a judgment of acquittal and her later motion for a new trial on a second-degree murder charge; the basis for that contention was Defendant's underlying assertion that the state failed to provide legally sufficient evidence for a jury to find that she acted with malice in connection with the death of her baby. Furthermore, Defendant contended that the trial justice erred in failing to grant her motion for a new trial because of what she alleged were improper comments made by the prosecutor during her closing argument. Upon review of the trial court record, the Supreme Court found no merit to Defendant's contentions on appeal, and affirmed her conviction. View "Rhode Island v. Robat" on Justia Law

Defendant James S. Richardson appealed his conviction by jury of first degree murder and burglary charges for which he was sentenced to life imprisonment without the possibility of parole. On appeal, Defendant argued that his conviction should have been vacated because the trial justice impermissibly allowed an expert witness called by the state to bolster the testimony of another of the state's expert witnesses. He also argued that the trial justice erred when he denied his motions for judgment of acquittal and for a new trial. Upon review of the trial court record, the Supreme Court affirmed the judgment of conviction. View "Rhode Island v. Richardson" on Justia Law

Applicant Eddy Guerrero appealed the denial of his application for postconviction relief. His sole contention on appeal was that the hearing justice erred in holding that his trial counsel provided effective assistance of counsel prior to and during Applicant's plea of nolo contendere. Specifically, Applicant contended: (1) that his counsel failed to obtain an interpreter for him at the time of the hearing on his motion to suppress certain evidence and at the time of his eventual plea; (2) that, prior to his execution of the plea form, his counsel failed to properly explain to him the essential elements of the offense to which he ultimately pled nolo contendere; (3) that his trial counsel failed to meet with him in a setting conducive to meaningful attorney-client communications; (4) that, by not conducting a sufficient investigation, his counsel failed to properly prepare for the suppression hearing; and (5) that the hearing justice erred in failing to address the prejudice component of the analysis relative to ineffective assistance of counsel allegations that is described in "Strickland v. Washington," (466 U.S. 668 (1984)). Upon review, the Supreme Court found none of Applicant's arguments on appeal to have merit, and affirmed the superior court's judgment. View "Guerrero v. Rhode Island" on Justia Law

Plaintiff Sofya Zharkopva appealed a family court judgment that dismissed her complaint against Defendant Paul Gaudreau. In her complaint, Plaintiff alleged she and Defendant were in a common-law marriage. At trial, after hearing testimony from the parties and from several other witnesses, the trial justice found that the plaintiff had failed to prove the existence of a common-law marriage by clear and convincing evidence; accordingly, he dismissed the plaintiff's complaint. On appeal, plaintiff contends that the trial justice's decision failed to do "substantial justice" between the parties and that the trial justice overlooked and/or misconceived relevant and material evidence or was otherwise "clearly wrong." After review of the family court record, the Supreme Court concluded that the trial justice did not misconceive or overlook relevant evidence, nor was he clearly wrong when he found that Plaintiff failed to prove by clear and convincing evidence that a common-law marriage existed between herself and the defendant. View "Zharkova v. Gaudreau" on Justia Law

The issue before the Supreme Court in this petition was whether G.L. 1956 section 5-6-2 permits only licensed electricians to install underground hollow polyvinyl chloride (PVC) material that is devoid of any electrical wiring or conductors. The Board of Examiners of Electricians, the Rhode Island Department of Labor and Training (DLT), and the Superior Court all determined that 5-6-2 required a licensed electrician to perform such work. The petitioners, Reilly Electrical Contractors, Inc. (Relco), Michael McSheffrey, Robert Rutledge, John Brewer, and Ray Bombardier, disagreed and petitioned the Court for a writ of certiorari. Upon review of the statute at issue here, the Court affirmed the judgment of the Superior Court. View "Reilly Electrical Contractors, Inc. v. Rhode Island" on Justia Law

At the end of a trial held in Kent County Superior Court, a jury found the defendant, James Cook guilty of twenty-two counts ranging from first-degree sexual assault to identity fraud. On appeal, defendant contended that the trial justice committed reversible error in denying his motion for a mistrial after the jury heard testimony that he had been on probation and also in admitting evidence of other prior sexual misconduct. Finding no error nor abuse of discretion, the Supreme Court affirmed the judgment of the Superior Court. View "Rhode Island v. Cook" on Justia Law