Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the superior court granting partial summary judgment in favor of Plaintiff in this foreclosure case, holding that there was no error in the proceedings below.Defendant signed a promissory note in favor of Plaintiff that consolidated numerous debts that Defendant owed Plaintiff in connection with various joint real estate projects. The promissory note was secured by a mortgage on certain real estate. When Defendant did not respond to a notice of default and demand for payment under the promissory note Plaintiff brought this action seeking injunctive relief and damages. Eventually, a second hearing justice granted Plaintiff's motion for partial summary judgment on counts one and two of her six-count complaint. The Supreme Court affirmed, holding that the second hearing justice properly applied the law of the case doctrine when granting Plaintiff's motion for partial summary judgment. View "DiMaggio v. Tucker" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Defendant, in her capacity as the Town of Lincoln's tax assessor, holding that Plaintiff was not entitled to relief on its claims of error.Plaintiff brought this action arguing that Defendant (1) illegally increased the value of Plaintiff's property in light of a solar energy development on a portion of Plaintiff's property for tax years 2019 and 2020, and (2) improperly created a new tax classification not recognized by R.I. Gen. Laws 44-5-11.8(b). The superior court granted judgment in favor of Defendant. The Supreme Court affirmed, holding (1) there was no error in including the presence of a solar energy development as an element of value assessed to real property; and (2) Plaintiff's claim that the tax assessor effectively created a new tax classification for property upon which a solar energy development is located, in contravention of R.I. Gen. Laws 44-5-11.8(b), was unpersuasive. View "Polseno Properties Management, LLC v. Keeble" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Plaintiff, Key Corporation, holding that Defendant, Greenville Public Library, was not entitled to relief on its two claims of error.Plaintiff filed a complaint seeing a declaratory judgment that Defendant violated the Access to Public Records Act (the APRA), R.I. Gen. Laws 1956 chapter 2 of title 38, and seeking an order directing Defendant to produce requested records pursuant to the APRA. Plaintiff argued that Defendant was a quasi-municipal corporation that received seventy percent of its funding from the Town of Smithfield and therefore was a "public body" or "agency" as defined by the APRA. The hearing justice determined that Defendant was a public body subject to the APRA and accordingly granted Plaintiff's motion for partial summary judgment. The Supreme Court affirmed, holding that the hearing justice (1) did not err in determining that Defendant was a public body; and (2) acted within his discretion in awarding fees and costs. View "Key Corp. v. Greenville Public Library" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the superior court following the grant of Flagstar Bank, FSB's motion for judgment on the pleadings and dismissing this action filed by Plaintiffs for wrongful acceleration, foreclosure, and sale of certain property, holding that the trial justice erred in part.In deciding Flagstar's motion for judgment on the pleadings, the trial court was required to resolve any doubts in favor of the complaining party. However, a disputed issue of material fact existed. The Supreme Court remanded the case in part, holding (1) the trial justice's failure to to resolve the disputed issue of material fact in favor of Plaintiffs, as the complaining party, was erroneous; and (2) the trial justice did not err in concluding that Flagstar complied with 24 C.F.R. 203.604. View "Montaquila v. Flagstar Bank, FSB" on Justia Law

The Supreme Court affirmed the decision of the Public Utilities Commission (PUC) denying the petition for a declaratory judgment filed by Block Island Power Company (BIPCo), holding that there were no grounds to overturn the PUC's decision.In 2009, the legislature enacted R.I. Gen. Laws 39-26.1-7 (the enabling act) authorizing the Town of New Shoreham Project. In 2017, BIPCo sought a declaratory judgment declaring that the enabling act required the costs for BIPCo's interconnection facilities and backup transformer to be socialized across all electric ratepayers in the state, not just those in the Town. The PUC issued a judgment against BIPCo. The Supreme Court affirmed, holding that the PUC's reading and application of the statute was without error. View "In re Block Island Power Co. Petition for Declaratory Judgment" on Justia Law

The Supreme Court affirmed the decision of the superior court granting summary judgment in favor of Defendants in this foreclosure action, holding that Plaintiff was not entitled to relief on his claims of error.Plaintiff executed a promissory note and mortgage secured by certain Pawtucket property. After Plaintiff defaulted on the loan, Defendants initiated the foreclosure process and sent Plaintiff the notice of sale. Plaintiff brought this complaint seeking to enjoin Defendants from proceeding with the foreclosure sale. The superior court denied Plaintiff's motion for a preliminary injunction and held a foreclosure sale. Thereafter, the trial judge granted Defendants' motion for summary judgment as to all of Plaintiff's claims. The Supreme Court affirmed, holding (1) were was no genuine issue of material precluding summary judgment; (2) the hearing justice did not err in finding that neither the default notice nor the amount of listed arrearage violated the mortgage or prejudiced Plaintiff; (3) the hearing justice properly disposed of Plaintiff's motions to strike; and (4) the hearing justice did not err in denying Plaintiff's motion to amend his original complaint. View "Degasparre v. Fay Servicing, LLC" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of six counts of neglecting an adult with severe impairments and sentencing him to concurrent five-year sentences at the Adult Correctional Institutions, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) Defendant's argument that R.I. Gen. Laws 11-5-12 is vague and ambiguous because it does not notify a potential criminal defendant what conduct is proscribed was without merit; (2) section 11-5-12 does not require expert medical testimony to establish “severe impairment”; (3) the trial justice did not misapply the law when he denied Defendant’s motion for a new trial; and (4) Defendant's argument that the state violated Sup. Ct. R. Crim. P. 16 was without not properly preserved for appeal and was further without merit. View "State v. Vose" on Justia Law

The Supreme Court vacated the judgment of the superior court granting Insurer's motion for summary judgment in this insurance dispute, holding that Insured was entitled to judgment as to counts one, four, and five of its complaint.Insured, a company that sold and serviced residential heating and air-conditioning systems, was sued by a former customer who alleged negligence and demanded remediation from property damaged by 170 gallons of home heating oil that leaked into his basement. Insured demanded that Insurer defend and indemnify against the claim. The hearing justice granted summary judgment in favor of Insurer. The Supreme Court vacated the judgment below, holding (1) the relevant insurance policy's definition of "pollution" was ambiguous as applied to Insured's claims; and (2) the hearing justice erred in granting summary judgment in favor of Insurer and in denying Insured's motion for summary judgment as to certain counts of the complaint. View "Regan Heating & Air Conditioning, Inc. v. Arbella Protection Insurance Co., Inc." on Justia Law

The Supreme Court affirmed the decision of the trial justice awarding attorneys' fees to Plaintiff in this divorce action, holding that there was no error.Plaintiff filed a complaint for divorce, and Defendant filed a counterclaim for divorce. As to attorneys' fees, the trial justice found that Plaintiff was entitled to reasonable attorneys' fees pursuant to the parties' postnuptial agreement's fee-shifting provision, as well as R.I. Gen. Laws 15-5-16. Defendant appealed, challenging the award of attorneys' fees. The Supreme Court affirmed, holding that the trial justice had both a statutory and contractual basis to award Plaintiff attorneys' fees and costs and did not abuse his discretion in making the award. View "McCollum v. McCollum" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Plaintiff in this case arising from a construction contract, holding that Defendant was not entitled to relief on his assignments of error on appeal.Specifically, the Supreme Judicial Court held that the trial justice (1) did not err in applying the doctrine of merger by deed; (2) did not make a mistake in calculating damages; (3) did not err in denying Defendant's claim that Plaintiff breached the parties' contract; (4) did not err in finding that the implied warranty of habitability did not apply to this case; and (5) properly found that the subcontractors' mechanics' liens were assignable to Plaintiff. View "Premier Land Development v. Kishfy" on Justia Law