Justia Rhode Island Supreme Court Opinion Summaries

In this dispute arising from an ill-fated attorney-client relationship the Supreme Court affirmed the judgment of the superior court grantinf Plaintiff's motion for summary judgment, holding that there was no error in the proceedings below.Plaintiff filed a complaint alleging breach of contract and seeking to recover almost $13,000 for unpaid services provided to Defendant and claiming that she was entitled to statutory interest, attorneys' fees, and costs of suit. The hearing justice granted Plaintiff's unopposed motion for summary judgment. The Supreme Court affirmed, holding that there was no disputed issue of material fact and that Defendant was liable for the outstanding balance due as payment for Plaintiff's services. View "Oliveira v. Levesque" on Justia Law

The Supreme Court vacated the judgment of the superior court in favor of Defendant, in his capacity as the finance director/treasurer for the Town of Smithfield, in this action challenging the calculation of a former employee's retirement benefits, holding that the court erred in concluding that Plaintiff had failed to exhaust his administrative remedies.Armand Beaudry worked as a firefighter for the Town for several years before he was placed on disability retirement benefits. The retirement benefits were governed by a pension system that constituted "an amalgamation of various documents." The case arose from a dispute over the calculation of Beaudry's benefits. Beaudry filed a complaint challenging the amount. The trial court granted the Town's motion for summary judgment based on failure to exhaust administrative remedies. The Supreme Court vacated the judgment, holding that the hearing justice erred by finding that a challenged amendment to the plan was enforceable at the time of Beaudry's retirement, thus creating an administrative remedy that Beaudry failed to exhaust. View "Beaudry v. Rossi" on Justia Law

The Supreme Court affirmed the order of the superior court denying Petitioner's petition for a writ of mandamus and dismissing his complaint pursuant to Sup. Ct. R. Civ. P. 12(b)(1) and 12(b)(6), holding that the superior court did not err.Plaintiff, a former employee of the City of East Providence, attempted to rescind an agreement he made with the City regarding, among other things, his retirement benefits and the issuance of a corrected W-2 to reflect his injured-on-duty status. The trial judge entered judgment for the City. Plaintiff then filed a complaint and petition for a writ of mandamus against his union asking the superior court to abrogate agreement regarding the period of his injured-on-duty status. The trial court granted Defendants' motion to dismiss. The Supreme Court affirmed, holding (1) several of Plaintiff's arguments were waived; and (2) this case was barred by res judicata. View "Jenkins v. City of East Providence" on Justia Law

The Supreme Court affirmed the decree of the family court terminating Father's parental rights to his daughter, R.M., holding that Father was not entitled to relief as to his arguments on appeal.The Department of Children, Youth, and Families (DCYF) filed a petition to terminate the parental rights of Father based on his incarceration and the child's placement the care of DCYF for more than twelve months. The trial justice ultimately determined that DCYF had met its burden of proof for the termination of parental rights petition by clear and convincing evidence and that termination of Father's parental rights was in the best interests of the child. The Supreme Court affirmed, holding that the trial justice did not err in (1) its finding as to parental unfitness; (2) finding that DCYF made reasonable efforts to "encourage and strengthen the parental relationship"; and (3) determining that it was in R.M.'s best interests for Father's parental rights to be terminated. View "In re R.M." on Justia Law

The Supreme Court quashed the order of the superior court granting Defendant's motion for a protective order limiting the deposition testimony of Plaintiff's expert witness to causation opinions and prohibiting Plaintiff from further supplementing the expert witness's disclosure to include other opinions, holding that the trial justice erred.Plaintiff brought this medical malpractice action alleging negligence. The trial justice later granted Defendant's motion for a protective order seeking to preclude the expert witness from offering opinions regarding the standard of care and prohibited Plaintiff from supplementing the witness's disclosure to include opinions on topics outside of causation, including standard of care. The Supreme Court quashed the decision below, holding that the trial justice abused her discretion in granting Defendant's motion. View "Vecchio v. Women & Infants Hospital" on Justia Law

The Supreme Court affirmed the judgment of the superior court declaring Defendant to be in violation of the terms and conditions of his probation, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that there was a lack of sufficient evidence to support a finding that he had violated his probation and, alternatively, that the trial justice imposed an excessive sentence for the violation. The Supreme Court affirmed, holding that the trial justice (1) did not act arbitrarily or capriciously in concluding that Defendant had violated his probation; and (2) did not abuse his discretion sentencing Defendant to thirty-six months of his suspended sentences, two months to remain suspended. View "State v. Perkins" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of felony assault resulting in serious bodily injury and sentencing him to a term of twenty years at the Adult Correctional Institutions, holding that any error was harmless.On appeal, Defendant argued that the trial justice erred in admitting evidence that he struck an unrelated person in an unrelated event earlier on the evening in question, in violation of R.I. R. Evid. 404(b) and 403. The Supreme Court affirmed the conviction, holding (1) the admission of the challenged evidence was an abuse of discretion; but (2) the error did not contribute to the jury's evaluation of the evidence and Defendant's conviction and amounted to harmless error. View "State v. DeCosta" on Justia Law

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