Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the superior court in favor of Hasbro, Inc. in this action alleging breach of an implied contract and other causes of action, holding that Appellants were not entitled to relief on appeal.Appellants, former Hasbro employees who now develop toy concepts, brought this complaint stemming from an action figure concept and play pattern that they developed, alleging that changes incorporated by Hasbro in its line of "Mashers" were virtually identical to the concept they had developed. Appellants brought this complaint alleging fraud, theft of intellectual property, and other causes of action. Judgment entered for Hasbro. The Supreme Court affirmed, holding that there existed no genuine issues of material fact precluding summary judgment. View "Wild Horse Concepts, LLC v. Hasbro, Inc." on Justia Law

The Supreme Court vacated the judgment of the superior court following a nonjury trial denying J.R. Vinagro Corporation's motion for attorneys' fees and costs against 96-108 Pine Street LLC, holding that the trial justice erred in finding that neither party prevailed in the litigation.Vinagro and Pine Street executed a demolition contract for a fixed fee. After work was disrupted, three parties filed separate cases. Following a nonjury trial, the trial justice issued a decision in favor of Vinagro on its breach of contract and unjust enrichment claims and in favor of Pine Street on its breach of contract claim. Vinagro and Pine Street each moved for attorneys' fees and costs based on section ten of the parties' contract. The trial justice declined to award either party attorneys' fees and costs. The Supreme Court vacated the judgment below, holding (1) the trial justice abused its discretion by not awarding Vinagro attorneys' fees and costs under the parties' demolition contract; and (2) the trial justice erred in concluding that Vinagro's unjust enrichment claim did not fall within the scope of the contract's fee-shifting provision. View "Clean Harbors Environmental Services, Inc. v. 96-108 Pine Street LLC" on Justia Law

The Supreme Court vacated the order of the superior court granting Defendant's motion to suppress two statements to Warwick police detectives in the course of their investigation, holding that the superior court abused its discretion.The trial justice suppress statements based on its findings that Defendant was in custody when he voluntarily accompanied the police detectives in an unmarked vehicle to search for evidence, that Defendant did not knowingly, intelligently, and voluntarily waive his Miranda rights, and that Defendant's video-recorded statement was inadmissible in accordance with Missouri v. Seibert, 542 U.S. 600 (2004). The Supreme Court vacated the superior court's order, holding (1) one of the statements at issue was admissible in evidence; and (2) remand was required for limited factual determination by the trial justice as to whether the other statement was a knowing, intelligent, and voluntary waiver of Defendant's Fifth Amendment rights. View "State v. Morillo" on Justia Law

The Supreme Court affirmed in part and vacated in part the order of the superior court granting summary judgment in favor of The Travelers Indemnity Company and denying Atmed Treatment Center's motion for summary judgment, holding that summary judgment was improperly granted on count three of the complaint.Folosade Olofinlade filed a charge of discrimination with the Rhode Island Commission for Human Rights alleging that Atmed's conduct against her and her brother-in-law constituted discrimination in violation of Title VII of the Civil Rights Act and other state and federal laws. Atmed demanded that Travelers defend it against the claims in accordance with a commercial general liability insurance policy that Atmed held with Travelers. Travelers disclaimed coverage. Thereafter, Olofinlade filed suit. Atmed commenced this action seeking a declaratory judgment that Travelers had a duty to defend Atmed before the Commission and asserting a breach-of-contract claim against Travelers. The trial court granted summary judgment for Travelers as to all counts. The Supreme Court reversed as to count three of the complaint, holding that because Travelers did not request summary judgment as to this count, the trial justice exceeded her authority in granting summary judgment as to that count. View "Atmed Treatment Center, Inc. v. Travelers Indemnity Co." on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Defendants and dismissing this suit in accordance with Sup. Ct. R. Civ. P. 37, holding that dismissal was warranted in this case.Plaintiff filed this action against Defendants, St. Thomas More Catholic Church, St. Peter's By-the-Sea Episcopal Church, and the Roman Catholic Bishop of Providence alleging that the excessive notice emanating from Defendants' bell towers was a nuisance and seeking more than $30 million in damages. The trial justice ultimately granted Defendants' motion to dismiss based on Plaintiff's answers to interrogatories, including an interrogatory requiring him to identify any expert witness he expected to call at trial. The Supreme Court affirmed, holding that Plaintiff's failure to provide a complete discovery response after repeated orders and admonitions by the trial court warranted dismissal. View "Devaney v. St. Thomas More Catholic Church" on Justia Law

In this real property dispute, the Supreme Court affirmed the judgment of the superior court for Defendants following the court's grant of summary judgment in favor of Defendants, holding that the trial justice did not err in ruling that the disputed land was a paper street and in finding that Plaintiff had failed to exhaust his administrative remedies.Plaintiff filed this action seeking a declaratory judgment that certain property was a public road that ran to the boundary of Plaintiff's property and that Plaintiff had the right to use the full length of the property and the right of access to his property. The superior court granted summary judgment for Defendants. The Supreme Court affirmed, holding that Plaintiff failed to exhaust his administrative remedies. View "Davis v. Town of Exeter" on Justia Law

The Supreme Court affirmed the decision and judgment of the superior court affirming the decisions of the Rhode Island Coastal Resources Management Council (CRMC) denying the application of Champlin's Realty Associates to expand its marina on the Great Salt Pond in the Town of New Shoreham, holding that there was no error.The trial justice found there was sufficient evidence to support the CRMC's denial of Champlin's application to expand its marina and held that the CRMC had acted within its authority in denying the application. Champlin's and the CRMC later filed a motion seeking to incorporate and merge a joint memorandum of understanding (the MOU) purporting to serve as the CRMC's decision relative to this matter into a consent order of the Court. Certain entities (intervenors) and the attorney general contested the propriety of the purported settlement and the validity of the MOU. The superior court affirmed. The Supreme Court affirmed and denied the request by Champlin's and the CRMC to incorporate and merge the MOU into a consent order of the Supreme Court, holding that the remand justice erred in determining that the CRMC and Champlin's had authority to meditate. View "Champlin's Realty Associates v. Coastal Resources Management Council" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the superior court in favor of Plaintiffs, Johnston Equities Associates, LP and Stay Away From the Cans, LLC on their trespass claim against Defendants, the Town of Johnston and its officials, for allowing sewage from the Town's sewer pipelines to be discharged into JEA's private sewer pipeline, holding that the trial justice erred in part.The jury awarded Plaintiffs $1.2 million in their favor, but the trial justice ruled that the statutory cap of $100,000 under R.I. Gen. Laws 9-31-3 was applicable because Plaintiffs' claim constituted a governmental function. The Supreme Court reversed in part, holding that the trial justice (1) properly denied the Town's motions for judgment as a matter of law; (2) did not err in not applying the public duty doctrine; but (3) erred in applying the statutory cap on damages and in denying prejudgment interest. View "Johnston Equities Associates, LP v. Town of Johnston" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting declaratory and injunctive relief in favor of Plaintiffs and denying declaratory and injunctive relief requested in a counterclaim filed by Defendants, holding that Defendants were not entitled to relief on their claims of error.On appeal, Defendants challenged the trial justice's ruling that a two-member condominium board consisting of the owners of the condominium's two units were not inconsistent with the R.I. Condominium Act, holding them in contempt, and awarding Plaintiffs attorneys' fees. The Supreme Court affirmed, holding (1) the superior court correctly denied Defendants' counterclaims; (2) the trial justice did not abuse its discretion in findings Defendants in civil contempt of a temporary restraining order; and (3) there was no abuse of discretion with respect to the trial justice's award of attorneys' fees. View "Anton v. Houze" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Defendant-union and denying Plaintiff's motion to vacate an arbitration award, granting Defendant's motion to confirm the award, and awarding attorneys' fees to Defendant as the prevailing party, holding that there was no error.Defendant represented certain municipal employees employed by Plaintiff, West Warwick Housing Authority. After Plaintiff suspended the employment of the grievant, Defendant grieved her termination pursuant to the parties' collective bargaining agreement (CBA). The arbitrator decided in the grievance's favor. Thereafter, Plaintiff filed a complaint seeking to vacate the arbitration award, arguing that the grievance was not substantively arbitrable because the CBA was invalid and that the arbitrator's decision was irrational. The superior court entered judgment in favor of Defendant. The Supreme Court affirmed, holding that the trial justice correctly denied Defendant's motion to vacate because the dispute was arbitrable. View "West Warwick Housing Authority v. R.I. Council 94" on Justia Law