Justia Rhode Island Supreme Court Opinion Summaries

Defendants Charles and Nancy Rogers and plaintiff Shelter Harbor Conservation Society owned contiguous lots in the same subdivision. The Society filed a complaint for declaratory judgment and injunctive relief against the Rogerses and town officials after the town zoning official issued zoning certificates designating three of the Rogerses lots for single-family residences, alleging that the certificates were void because they were issued after a merger of the lots. The superior court eventually granted summary judgment to the Rogerses, finding the lots were unmerged pursuant to the merger provision of the zoning ordinance. The Society appealed, contending (1) the evidence contained divergent interpretations of the map depicting the Rogerses' lots, and therefore the trial justice therefore improperly weighed the evidence at the summary-judgment stage and a trial on the merits was necessary to resolve the issue; and (2) the trial justice erred when she stayed the Society's attempts to obtain discovery from the Rogerses. The Supreme Court affirmed, holding (1) as a matter of law, the map was unambiguous; and (2) the trial justice did not abuse her discretion in staying deposition notices that were not intended to obtain information relevant to the issue under consideration. View "The Shelter Harbor Conservation Society, Inc. v. Rogers, et al." on Justia Law

Defendant Viroth Phannavong was convicted of three counts of child molestation against his former girlfriend's daughter. At trial, defendant sought to introduce a map of Woonsocket, Rhode Island, which depicted the defendant's former home. The trial justice sustained the state's objection to the map being admitted as a full exhibit, arguing that it could not be authenticated properly. The defendant also moved for a new trial because the verdict failed to do substantial justice between the parties, a motion the trial justice denied. On appeal, the defendant argued that the trial justice erred (1) by refusing to admit into evidence a map of Woonsocket, and (2) by denying his motion for a new trial. The Supreme Court affirmed, finding no reason to disturb the trial justice's findings as (1) the map was neither properly authenticated nor was its reliability established, and (2) the trial justice clearly conducted a thorough review of the credibility of the witnesses and the weight of the evidence to support the verdict. View "State v. Phannavong" on Justia Law

Defendant Nicholas Gianquitti was convicted of second-degree murder and using a firearm while committing a crime of violence. During trial, the trial justice found that there was nothing that would suggest that defendant intended to prevent entry into his home and that, therefore, there was no evidence of a breaking and entering crime in accordance with R.I. Gen. Laws 11-8-8. Defendant appealed, arguing that the trial justice erred (1) by refusing to instruct the jury in accordance with Section 11-8-8 and denying his subsequent motion for a new trial on the same basis; and (2) by excluding expert testimony. The Supreme Court affirmed, holding (1) that after reviewing the evidence, there was no reason to disturb the findings of the trial justice regarding defendant's Section 11-8-8 argument; and (2) because defendant failed to renew his objection on the issue of admissibility of expert testimony and did not preserve the issue for appellate review, the admissibility of expert opinion testimony was waived. View "State v. Gianquitti" on Justia Law

Defendant James Enos dated Mary for six months before they separated. After their separation they met at a restaurant where defendant began swearing at Mary. Defendant then hit Mary on the head with drinking glasses and kicked her. Defendant was convicted of domestic assault with a dangerous weapon. Defendant appealed, arguing (1) that the evidence presented by the state was legally insufficient for a reasonable juror to conclude that defendant and Mary were in a domestic relationship; and (2) the trial justice erred when she refused to declare a mistrial after a police officer testified that after defendant was informed of his Miranda rights defendant remained silent. The Supreme Court affirmed, holding (1) the evidence, overall, indicated that defendant and Mary were in a substantive dating relationship and therefore the trial justice correctly denied defendant's motion for a judgment of acquittal; and (2) the trial justice was not clearly wrong when she denied the defendant's motion for a mistrial and instead opted to instruct the jury to disregard the officer's unsolicited remark. View "State v. Enos" on Justia Law

Plaintiff Kathy Lamarque executed a mortgage with defendant Centreville Savings Bank. After defaulting on another loan for a second mortgage on the same property, defendant disclosed the balance of plaintiff's mortgage to the purchaser of plaintiff's property at a foreclosure sale. Plaintiff filed a complaint against defendant for negligence and a violation of plaintiff's privacy rights. At trial, defendant moved for a judgment on partial findings, which the trial court granted. Plaintiff appealed, arguing that her right to privacy was violated by defendant and that the Gramm-Leach-Bliley Act and defendant's privacy policy created a legal duty to protect private information from disclosure. The Supreme Court affirmed, holding that under the facts of the case, plaintiff's privacy rights were not violated and defendant did not breach its duty to plaintiff. View "Lamarque v. Centreville Savings Bank" on Justia Law

Plaintiff Deborah Dawkins was treated by defendant David Siwicki during an emergency room visit after the plaintiff fell and injured her left wrist. The plaintiff subsequently filed a medical malpractice lawsuit, alleging negligent diagnosis and treatment by the defendant. The plaintiff was initially treated by the defendant and subsequently underwent multiple surgeries over the span of several years, which the plaintiff alleged were necessary because of the defendant's alleged negligent treatment of her injury. The jury returned a verdict for the defendant. The plaintiff appealed, raising a number of arguments before the Supreme Court, many of which centered around the defense of the plaintiff's comparative negligence based on the defendant's contention that cigarette smoking impeded her treatment. The Supreme Court affirmed the judgment of the superior court, finding the trial justice did not abuse his discretion in the arguments raised by the plaintiff regarding pretrial ruling matters, alleged trial errors, and posttrial motions. View "Dawkins v. Siwicki" on Justia Law

Plaintiff City of Providence filed a complaint against John Doe et al. and Jane Doe et al., unknown defendants, for trespassing on city-owned land by setting up an encampment. The complaint sought injunctive relief enjoining defendants from trespassing on the property. The trial court granted plaintiff's motion for a preliminary injunction. The defendants appealed, arguing (1) the trial court improperly denied their motion to dismiss for lack of subject-matter jurisdiction, (2) because other remedies at law may exist, the grant of equitable relief was inappropriate, and (3) the preliminary injunction failed for indefiniteness because it applied only to unknown persons and therefore was unenforceable at a contempt proceeding. The Supreme Court affirmed, holding (1) the superior court had subject-matter jurisdiction and R.I. Gen. Laws 8-8-3(a)(2) did not divest the court of jurisdiction, (2) because the trespass was continuous injunctive relief was appropriate, and (3) the terms of the order were specific enough to enable someone reading the injunctive order to understand what he or she may not do under it. View "City of Providence v. John Doe, et al." on Justia Law

In 2006, defendant Edgar Goulet killed his dog by shooting it with a sawed-off shotgun. One year later, the state, by way of criminal information, charged defendant with one count of malicious killing of an animal and one count of possession of a sawed-off shotgun. At trial, among other motions, defendant filed a motion to sever to the two counts of the information. The motion to sever was denied. After a jury trial defendant was convicted on both counts. The defendant appealed. The issues properly before the Supreme Court were (1) defendant's assertion that the trial justice erred when he denied defendant's motion to sever, and (2) the defendant's Fourth Amendment claims relating to the police officers' searches of the defendant's yard and home. The Court affirmed, concluding (1) the defendant did not make a sufficient showing that he would be prejudiced to the extent that he would not receive a fair trial if the two counts were not severed, and thus the trial justice did not abuse his discretion when he denied defendant's motion; and (2) the defendant's Fourth Amendment claims as to the propriety of the warrantless search were without merit. View "State v. Goulet" on Justia Law

Citizens Bank filed a complaint against Howard Issler, seeking to recover funds allegedly owned to the bank in connection with a line of credit that the bank had extended to him. After judgment was entered against Howard and execution was returned unsatisfied, Citizens filed for a writ of attachment. Kymberly Issler, who had a joint account with Howard, then intervened in the civil action, objecting to the attachment and to the release of any funds to Citizens. A hearing officer granted the attachment. Citizens then filed a motion to charge garnishee to reach funds in the personal account. After a hearing, an order was entered granting Citizens' motion to charge garnishee and denying Kymberly's objection to the attachment of funds. The Supreme Court affirmed, concluding that, according to precedent, a bank has a right to use funds in a joint account to set off the debt of one account holder, regardless of whether that holder contributed any funds to the account. The Court then held that Citizens had a right to set off Howard's debt with the funds in the joint account to which he and Kymberly were signatories. View "RBS Citizens Bank, N.A. v. Issler" on Justia Law

Defendant Raymond Staffier was charged with four counts of second-degree child molestation. The case was submitted to the jury, and a verdict of not guilty was returned on count one with a finding of guilt on the remaining three counts. Defendant filed a pro se appeal, arguing that the trial justice erred (1) by denying his motion for a new trial because the inconsistent verdicts fail to do substantial justice and that this inconsistency cannot logically be explained, and (2) by allowing one of the state's witnesses to testify in contravention of a sequestration order. The Supreme Court affirmed, holding that (1) because the trial justice considered the evidence and ultimately found that the verdict was strongly supported by the evidence, the justice's inquiry rightfully ended when she agreed with the jury's verdict; and (2) because any violation of the sequestration order was unintentional, the testimony did not undermine the purpose of the sequestration order, and any potential harm to the defendant was addressed by the trial justice, the trial justice did not abuse her discretion when she allowed the testimony. View "State v. Staffier" on Justia Law