Justia Rhode Island Supreme Court Opinion Summaries

Plaintiff James Casale was employed by Defendant City of Cranston when he was injured. During his incapacity, Plaintiff received injured-on-duty (IOD) benefits from the City. In accordance with its policy with Plaintiff, Plaintiff's insurer, Amica Mutual Insurance Company, tendered $100,000 in uninsured motorist benefits to Plaintiff minus the amount that the City paid to Plaintiff for IOD benefits. Plaintiff subsequently initiated this declaratory judgment action seeking a judicial determination that R.I. Gen. Laws 45-19-1.1, which requires that an employer be reimbursed out of the proceeds received from the third party, was inapplicable to his case and that the City was not entitled to reimbursement from uninsured motorist benefits Plaintiff recovered under the policy. The trial justice concluded that the City was not entitled to reimbursement. The Supreme Court affirmed, holding (1) the trial justice correctly held that Defendant was not entitled to reimbursement for the IOD payments paid to Plaintiff; and (2) because Plaintiff did not collect any money from the tortfeasor, section 45-19-1.1 was inapplicable to this case. View "Casale v. City of Cranston" on Justia Law

Applicant Jerry Steele entered a plea of nolo contedere to assault with a dangerous weapon. Applicant subsequently filed a pro se motion for postconviction relief, alleging, inter alia, that he was forced against his will to enter a guilty plea. After the superior court appointed an attorney for applicant, the court denied the motion. Applicant appealed, contending that his court-appointed attorney provided ineffective assistance of counsel during the postconviction-relief hearing. The Supreme Court affirmed, holding that Applicant's contention concerning alleged ineffective assistance of counsel at the postconviction-relief hearing was not property before it, as Applicant's argument on appeal was not presented to the superior court. View "State v. Steele" on Justia Law

Defendant Yoneiry Delarosa appealed from a superior court judgment adjudicating him a violator of probation. The Supreme Court affirmed the judgment of the superior court, holding that the hearing justice did not err (1) by crediting the testimony of a witness after she was offered a favorable plea disposition by the State to testify against Defendant; (2) in overruling defense counsel's objection to certain testimony by the witness about which Defendant alleged he had not been apprised prior to the hearing because the witness revealed the information for the first time at the hearing and no written or recorded statement existed on this particular issue; and (3) by failing to allow defense counsel or Defendant the opportunity to address the court prior to sentencing, as the hearing justice correctly followed precedent in so ruling. View "State v. Delarosa" on Justia Law

Trustee sought an order allowing him to remove the life tenant (Defendant) from property owned by the trust. The probate court issued an order in conformity with Trustee's petition after Defendant was defaulted for failing to appear. Defendant filed a complaint in superior court purportedly appealing from the decision of the probate court. The trial justice concluded that Defendant had failed to comply with the requirements for filing a claim of appeal from the probate court and granted Trustee's motion to dismiss. The Supreme Court affirmed, holding that the superior court lacked jurisdiction to entertain Defendant's appeal for failure to comply with every relevant provision of the statute governing appeals from the probate court, and therefore, the superior court did not err in its judgment. View "Ims v. Audette" on Justia Law

Defendant Christopher Smith was found guilty of first-degree child molestation sexual assault and second-degree child molestation sexual assault arising from a series of assaults upon a thirteen-year-old girl. The Supreme Court affirmed, holding that the trial justice did not abuse his discretion by (1) denying Defendant's motion for a new trial, as there was sufficient evidence to support the jury's verdict; and (2) permitting the State, over Defendant's objection, to cross-examine Defendant about weapons training he received while in the military, as the trial justice properly weighed the probative value of the evidence against any potential prejudicial effect in overruling Defendant's objection. View "State v. Smith" on Justia Law

The family court terminated Father's parental rights to his daughter, Gabrielle D., after Gabrielle had been placed with the Department of Children, Youth and Families (DCYF) for at least twelve months. Father appealed. The Supreme Court affirmed, holding (1) the trial justice did not clearly err in finding that DCYF had made reasonable efforts to reunify Gabrielle and Father pursuant to R.I. Gen. Laws 15-7-7(a)(3); and (2) as Father's remaining allegations of error involved statutory provisions other than section 15-7-7(a)(3), and in view of the Court's holding that the trial justice did not clearly err with respect to section 15-7-7(a)(3)'s reasonable efforts requirement, the other claims of error did not need to be addressed. View "In re Gabrielle D." on Justia Law

Defendant Isabel Traveras was convicted of possession of an enumerated quantity of cocaine, for which she received a ten-year suspended sentence, with probation. On appeal, Defendant challenged the denial of her motion to suppress, alleging that the arresting police officers violated her Fourth Amendment rights when they (1) detained her unlawfully at a traffic stop and conducted a pat-down search without a reasonable articulable suspicion that she might be armed and dangerous, and (2) exceeded the scope of a permissible pat-down search by directing her to unzip and open her jacket. The Supreme Court affirmed, holding that, based on the totality of the circumstances, (1) the officers acquired the requisite reasonable suspicion to approach Defendant in the vehicle in which she was sitting as a passenger; and (2) the credible evidence was sufficient to establish that an officer's request to Defendant to open her jacket was reasonable and was a less-intrusive search designed to ensure officer safety. View "State v. Taveras" on Justia Law

Defendant Robert Payette was convicted of first-degree murder, for which he received a sentence of life imprisonment. Payette appealed, contending that the trial justice erred (1) by instructing the jury that malice may be inferred where there is a disparity in the size or strength between the victim and the defendant; and (2) by denying his motion for a new trial. The Supreme Court affirmed, holding (1) the instruction at issue was a correct statement of law and was not improper; and (2) the trial justice properly denied Payette's motion for a new trial, as there was nothing in the record that would indicate that the justice overlooked or misconceived any material evidence or otherwise clearly erred. View "State v. Payette" on Justia Law

Because Property Owner failed to pay real estate taxes on his property, the Town held a tax sale of Property Owner's property. Buyer purchased the property after Property Owner defaulted on the action. The superior court subsequently granted Buyer's petition to foreclose Property Owner's right of redemption to the property. Subsequently, a judgment was entered declaring the prior tax sale void and vesting the property back to Property Owner. Property Owner then executed a warranty deed conveying the property to his Sister. Concurrently, a stipulation was entered as an order of the superior court vesting title in the property to Buyer. Thereafter, Property Owner and Sister filed the instant action, seeking a declaratory judgment invalidating the stipulation order. The superior court determined that Buyer was the proper record title holder of the property. The Supreme Court affirmed, holding that a superior court judgment cannot "re-vest" title to property back to a prior owner once that owner has been defaulted in a petition to foreclose his right of redemption and a final decree has been entered. View "Medeiros v. Bankers Trust Co." on Justia Law

Defendant Allen Wray was convicted by a jury of two counts of first-degree robbery after robbing two women at gunpoint. Defendant appealed, arguing that the trial justice erred in (1) denying Defendant's motion for a new trial, as the eyewitness identifications that led to his conviction were unreliable and not substantial enough to prove beyond a reasonable doubt that he committed the robberies in question; and (2) allowing another witness to vouch for the credibility of the two witnesses. The Supreme Court affirmed, holding that the trial justice did not err in (1) denying Defendant's motion for a new trial, as the justice sufficiently articulated his rationale for denying Defendant's motion and did not overlook or misconceive any material evidence; and (2) allowing certain testimony into evidence, as the testimony did not constitute impermissible bolstering. View "State v. Wray" on Justia Law