Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant Emmanuel Karngar was found guilty of breaking and entering. Defendant appealed, arguing that his motion for a new trial should have been granted based on the lack of credibility of the complaining witness, the lack of evidence in light of the charge, and the overall insufficiency of the evidence. The Supreme Court affirmed the superior court, holding (1) Defendant's motion for a new trial failed to challenge the sufficiency of the evidence, and therefore the Court declined to decide that claim; and (2) the trial justice did not abuse his discretion in finding that reasonable minds could disagree about the witnesses' credibility and that the verdict was not against the weight of the evidence. View "State v. Karngar" on Justia Law

The insurance coverage dispute at issue in this appeal stemmed from a civil action brought by Ronald and Mildred Destremps against Viking Stone for allegedly damaging property. At the time, Viking Stone was insured by Employers, the plaintiff in the instant case. Arbella, the defendant in the instant case, had previously provided insurance coverage to Viking Stone. Employers filed a petition for declaratory judgment in superior court, seeking a declaration (1) that Arbella owed a duty to defend and indemnify Viking Stone in connection with the Destrempts' complaint, and (2) that the facts claimed in the Destrempts' complaint triggered one occurrence under the Arbella policy and that, for that reason, no coverage was afforded to Viking Stone under the Employers policy. The superior court granted Employers' motion for partial summary judgment, and Arbella appealed. The Supreme Court vacated the judgment of the superior court, holding that genuine issues of material fact precluded the grant of summary judgment. Remanded. View "Employers Mut. Casualty Co. v. Arbella Protection Ins. Co." on Justia Law

While traveling in a vehicle insured by Travelers Insurance, Wayne DeMarco was injured in a collision. DeMarco filed a personal injury action against Travelers. The trial court entered judgment in favor of DeMarco for $2,801,939, including interest. DeMarco then commenced the instant civil action against Travelers in the superior court, demanding, inter alia, (1) a declaratory judgment ordering Travelers to pay the entire judgment from the personal injury litigation above and beyond the $1 million policy limits, and (2) a declaratory judgment pursuant to the rejected settlement offer statute requiring Travelers to pay interest on the entire amount. The superior court granted partial summary judgment in favor of DeMarco, holding (1) Travelers was liable to DeMarco for the entire judgment even in a multiple claimant context, and (2) the rejected settlement offer statute was unambiguous in providing that an insurer is liable for interest due on a judgment where it has rejected a plaintiff's written offer to settle within the policy limits. On appeal, the Supreme Court (1) vacated the grant of partial summary judgment as to Travelers' liability, but (2) affirmed the ruling with respect to the applicability of the rejected settlement offer statute. Remanded. View "DeMarco v. Travelers Ins. Co." on Justia Law

Anthony DeCiantis was convicted of murder in the first degree and received a life sentence. DeCiantis filed a third application for postconviction relief, the subject of this appeal, alleging, inter alia, prosecutorial misconduct and that the prosecution intentionally withheld an uncharged act admitted to by one of its witnesses. The superior court dismissed the application, and DeCiantis appealed. The Supreme Court affirmed, holding (1) the hearing justice did not err in his determination that no prosecutorial misconduct occurred, and (2) although the witness's uncharged crimes should have been disclosed to DeCiantis, DeCiantis did not satisfy his burden of showing that the nondisclosed evidence was material. View "DeCiantis v. State" on Justia Law

Defendant Mark Sampson was convicted for second degree child abuse in superior court pursuant to R.I. Gen. Laws 11-9-5.3, otherwise entitled Brendan's Law. Defendant appealed, making several arguments, including that the trial justice erred because (1) Brendan's Law was unconstitutionally vague; and (2) Defendant did not knowingly, intelligently, and voluntarily waive his right to counsel. The Supreme Court reversed, holding that the trial justice erred in forcing Defendant to choose to defend himself pro se or proceed to trial with an attorney who refused to implement Defendant's personal right to waive a jury, and thus Defendant never knowingly, intelligently, and voluntarily waived his right to counsel. The Court did not address the remainder of Defendant's arguments except to impart a specific instruction to the superior court with respect to the proceedings on remand, holding it was error for the trial justice to construe Brendan's Law to, in effect, delete the word "serious" in the statute. Accordingly, an adjudication that a defendant is guilty of second degree child abuse requires a determination as to whether the defendant inflicted a serious physical injury. Remanded. View "State v. Sampson" on Justia Law

After a jury trial, defendant Tracey Barros was convicted of conspiracy to commit murder, first-degree murder, discharging a firearm while committing a crime of violence, and unlawfully carrying a firearm without a license. On appeal, Defendant contended that the trial justice erred when he (1) denied Defendant's motion to suppress his confession, and (2) precluded cross-examination of a prosecution witness with respect to purported third-party-perpetrator evidence. The Supreme Court affirmed, holding (1) the trial justice did not err in denying Defendant's motion to suppress as a review of the record revealed that Defendant's statements were voluntary and the timing of Defendant's presentment was not operative in inducing him to make his confession; and (2) the trial justice did not err in granting the prosecution's motion in limine to preclude the admission of third-party-perpetrator evidence because Defendant did not offer evidence reasonably specific to establish (a) that the individuals referred to had an opportunity to commit the crime or (b) a proximate connection between the individuals and the victim. View "State v. Barros" on Justia Law

Plaintiff North End Realty, a developer, filed a complaint in superior court seeking declaratory and injunctive relief against defendants, the town planner, finance director, and members of the town council of East Greenwich, after the town mandated that North End pay a $200,000 fee-in-lieu before it could record any subdivision approval it might receive from the planning board and begin to develop property. The hearing justice ruled that North End had failed to establish there was a likelihood of success of its claim and entered judgment in favor of defendants. On appeal, North End made several arguments, one of which was that the town did not have the requisite statutory authority to impose the fee-in-lieu. The Supreme Court vacated the judgment of the superior court, holding that the town may not legally impose a fee-in-lieu in the absence of enabling authority from the general assembly. Remanded with directions to issue an order enjoining the town from imposing, assessing, or collecting the fee-in-lieu. View "North End Realty, L.L.C. v. Mattos" on Justia Law

This case involved an alleged easement on plaintiffs' property used by defendant development company. Plaintiffs sued for injunctive relief, alleging that defendant had violated the warranty covenants in the deed that conveyed the property in dispute from defendant to plaintiffs. The trial court ruled that the easement was valid. The Supreme Court reversed and remanded. On remand, plaintiffs filed a motion for an award of attorneys' fees, damages and costs. The superior court granted defendant's motion for summary judgment, finding that plaintiffs were not entitled to an award of attorneys' fees for the successful defense of title under a general warranty deed. The Supreme Court affirmed, finding that warranty covenants do not entitle the grantee to recover attorneys' fees from the grantor for a successful defense of title even where it is the grantor who attacks the title. View "Nunes v. Meadowbrook Dev. Co." on Justia Law

Plaintiff Harodite Industries filed a complaint against defendant Warren Electric for negligence and other causes of action, seeking damages for the failure of a gasket in the oil pre-heater that Harodite purchased from defendant. After conducting discovery, Harodite filed a motion to amend its complaint. The hearing justice denied Harodite's motion. Plaintiff then filed a motion for a stay pending a ruling on the petition for writ of certiorari it intended to file with the Supreme Court. Defendant objected to the motion, arguing that the court should apply a Massachusetts statute of limitations to plaintiff's proposed amended complaint. The hearing justice held that Rhode Island's ten-year statute of limitations should apply and granted Harodite's motion for a stay. The Supreme Court affirmed the rulings of the superior court, holding (1) the hearing justice did not abuse her discretion in denying Harodite's motion to amend its complaint; and (2) the hearing justice correctly determined that Rhode Island's statute of limitations would be the relevant statute of limitations with respect to the allegations set forth in Harodite's proposed amended complaint, and therefore, those allegations would not be barred by the statute of limitations. View "Harodite Industries, Inc. v. Warren Electric Corp." on Justia Law

The state public utilities commission approved a power-purchase agreement (PPA) between National Grid and Deepwater Wind, the respondents. Under the PPA, Deepwater Wind agreed to construct an offshore wind farm in state waters and then sell the generated electricity to National Grid, a statewide power distributor. National Grid, in turn, pledged to purchase the generated electricity and apportion the cost of building the wind farm to in-state ratepayers over the course of the twenty-year contract. Dissatisfied with National Grid's cost-distribution plan, petitioners Toray Plastics and Polytop challenged the commission's assessment that the PPA met all statutory preconditions for approval. The Supreme Court affirmed the commission's decision, concluding that the commission accurately interpreted and applied the law by making findings that were lawful and reasonable, fairly and substantially supported by legal evidence, and sufficiently specific for the Court to ascertain that the evidence upon which the commission based its findings reasonably supported the result. View "In re Review of Proposed Town of New Shoreham Project" on Justia Law