Justia Rhode Island Supreme Court Opinion Summaries

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

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