Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court vacated the judgment of the superior court in favor of Plaintiff on its claims of trespass and encroachment and against Defendants on their counterclaim for adverse possession, holding that the trial justice erred in deciding that Defendants failed to satisfy the open and notorious elements of their adverse possession claim.Plaintiff, The Union Cemetery Burial Society of North Smithfield, brought this complaint alleging that Defendants, John and Donna Foisy, had encroached and trespassed on its property at two locations. Defendants filed a counterclaim seeking declaratory and injunctive relief to quiet title pursuant to the doctrine of adverse possession. The trial justice ruled that Plaintiff was entitled to declaratory relief as well as a permanent injunction restraining and enjoining Defendants from further trespass. The Supreme Court vacated the lower court's order and remanded the case for further proceedings, holding that the trial justice overlooked or misconstrued material evidence and failed to take into account relevant and instructive caselaw. View "Union Cemetery Burial Society of North Smithfield v. Foisy" on Justia Law

The Supreme Court affirmed the decree of the family court in favor of Mother and permitting Mother to vaccinate the parties' two minor children for COVID-19 consistent with the recommendation of the children's pediatrician, holding that there was no error.In 2020, the family court entered a final judgment of divorce between the parties setting forth provisions governing the children's custody and visitation, including the provision that "[n]either party shall unreasonably withhold his or her consent to medical treatment for the children or the administration of medication recommendation by the pediatrician of the children." In 2022, Plaintiff filed a motion for relief after final judgment seeking the court's permission to vaccinate the children for COVID-19, consistent with the pediatrician's recommendation. The trial justice allowed the motion. The Supreme Court affirmed, holding that the trial justice's factual findings did not overlook or misconceive any aspect of the matter, nor were they otherwise clearly wrong. View "Nagel v. Nagel" on Justia Law

The Supreme Court vacated the judgment of the superior court entered favor of Allstate Property and Casualty Insurance Company in this breach of contract action, holding that, under the circumstances, the court erred in granting Allstate's motion for summary judgment.Plaintiff made a claim for loss under its homeowners policy with Allstate after a water loss Plaintiff's property suffered. While Plaintiff sought to invoke a provision in the policy that either party could seek appraisal in the event of a dispute as to the amount of the loss Allstate refused to proceed to appraisal. Plaintiff filed suit for breach of contract in his first action. Allstate counterclaimed seeking a declaration that the parties were required to submit the matter to appraisal. The trial justice granted summary judgment for Allstate without prejudice. Thereafter, Plaintiff demanded that Allstate move forward with the appraisal process. Allstate refused, asserting that Plaintiff's demand was untimely under the policy. Plaintiff then commenced the instant action seeking relief in the form of a judgment ordering Allstate to designate an appraiser and to complete the appraisal process. Final judgment entered for Allstate. The Supreme Court vacated the judgment below, holding that Plaintiff's initial demand for appraisal was not time-barred, and therefore, the trial court erroneously granted summary judgment for Allstate. View "Romeo v. Allstate Property & Casualty Insurance Co." on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Defendants in this dental malpractice action following the grant of Defendants' motion for summary judgment, holding that the superior court correctly found that Plaintiff's complaint was time-barred.Plaintiff filed a dental malpractice claim against Defendants, and Defendants filed answers asserting affirmative defenses related to the statute of limitations. The superior court granted summary judgment and final judgment in favor of Defendants, determining that Plaintiff's complaint was not timely filed. The Supreme Court affirmed, holding that Plaintiff's dental malpractice claims against Defendants were time-barred. View "Smith v. Paquette" on Justia Law

The Supreme Court affirmed the judgments of the superior court granting six motions for summary judgment in three underlying cases, holding that the motion justice did not err by ordering reformation of the warranty deeds of both Raymond Burt and Tammy Lacoste and the mortgage deed of Burt.The superior court's order of reformation was based on the uncontested facts that the warranty deeds and mortgage deed at issue did not reflect the parties' intent and the motion judge's conclusion that the deeds were the product of a mutual mistake. The Supreme Court affirmed, holding (1) uncontested evidence in the record clearly and convincingly demonstrated that the warranty deeds and mortgage deed failed correctly to express the parties' agreement and were thus the product of mutual mistake; and (2) summary judgment was properly granted with respect to each of the six motions for summary judgment. View "Burt v. Furtado" on Justia Law

The Supreme Court affirmed the decree of the family court issued pursuant to R.I. Gen. Laws 15-7-7(a)(3) terminating Father's parental rights to his son, J.B. holding that there was no error in the proceedings below.The Department of Children, Youth, and Families filed a petition in the family court to terminate the parental rights of Father based on two grounds of unfitness. After a trial, the trial justice found clear and convincing evidence that Father was not a fit parent who could care for J.B. immediately and that it was in J.B.'s best interests to terminate Father's parental rights. The Supreme Court affirmed, holding that competent evidence supported the findings of the trial justice that Father was an unfit parent pursuant to section 15-7-7(a)(3) and that termination of Father's parental rights was in J.B.'s best interests. View "In re J.B." on Justia Law

The Supreme Court affirmed the order of the superior court denying Defendant's motion for a new trial after judgment entered in favor of Plaintiff, Ocean State Credit Union, in its action seeking money owed on a promissory note, holding that the trial justice did not overlook or misconceive material evidence and was not otherwise clearly wrong.Defendant entered into an agreement to repay a $3,000 loan that he had received from Plaintiff. Plaintiff later brought this action seeking $2,250 owed on the promissory note plus contractual interest. Final judgment entered in favor of Plaintiff. Thereafter, Defendant filed a motion for a new trial. When he learned the trial justice would hear the motion in Providence County instead of Kent County where the proceedings had previously been held, Defendant filed a motion to quash the change of venue. The trial justice denied relief. The Supreme Court affirmed, holding (1) the trial justice did not err in denying Defendant's motion for a new trial; and (2) Defendant's remaining contentions were without merit. View "Ocean State Credit Union v. Menge" on Justia Law

The Supreme Court affirmed the judgment of the superior court in granting summary judgment in favor of Defendants, Rhode Island College and related individuals, on the grounds of qualified immunity, holding that Plaintiff was not entitled to relief on his claims of error.Plaintiff brought this action seeking equitable relief and damages under 42 U.S.C. 1983 and 1988 on the grounds that Defendants' conduct toward him during his Master of Social Work program violated his First and Fourteenth Rights. The superior court concluded that Defendants were entitled to qualified immunity and granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding that Plaintiff's arguments on appeal were unavailing. View "Felkner v. R.I. College" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the superior court in favor of Defendant following the court's summary judgment and grant of motions to strike in favor of Defendant, holding that the hearing justice erred when he granted Defendant's motion for summary judgment as to count five of Plaintiff's complaint.Plaintiff filed a complaint alleging five counts against Defendant stemming from the purchase and lease of a commercial property. A hearing justice granted Defendants' motions to strike an expert disclosure and an affidavit. The Supreme Court vacated the judgment in part, holding that the hearing justice (1) properly granted Defendant's motion to strike the affidavit; but (2) erroneously granted summary judgment as to count five of the complaint. View "Donnelly Real Estate, LLC v. John Crane Inc." on Justia Law

The Supreme Court affirmed the decision of the superior court granting summary judgment and final judgment in favor of third-party defendants, Western Surety Company and the Insurance Company of the State of Pennsylvania (collectively, the Sureties) in this case concerning the scope of the sureties' liability under a performance and payment bond issued in conjunction with a public works project, holding that there was no error.The Rhode Island Department of Transportation (RIDOT) was sued by Apex Development Company in this action alleging that RIDOT and its contractors trespassed and damaged Apex's private property. RIDOT filed a third-party complaint against the Sureties and others, seeking full indemnity and contribution. A hearing justice granted summary judgment for the Sureties, and a final judgment was entered. The Supreme Court affirmed, holding that RIDOT was not entitled to relief on its allegations of error on appeal. View "Apex Development Co., LLC v. State of R.I. Dep't of Transportation" on Justia Law