Justia Rhode Island Supreme Court Opinion Summaries

A deputy sheriff employed by the Rhode Island Department of Public Safety applied for both ordinary and accidental disability retirement pensions, claiming a back injury sustained in 2011 caused him to stop working in 2020. The Employees’ Retirement System of Rhode Island’s Disability Committee recommended approval of only the ordinary disability pension, finding the accidental disability claim untimely under the statutory filing limits, and noting no evidence of an intervening injury or aggravation. The state retirement board adopted this recommendation and denied the accidental disability pension. Despite submitting additional evidence and requesting rehearing and further medical evaluation, the deputy sheriff’s application continued to be denied by the board, which advised that any appeal could be made in the Superior Court or the Workers’ Compensation Court, if applicable.Following these denials, the deputy sheriff filed appeals in both the Superior Court and the Workers’ Compensation Court. The Employees’ Retirement System moved to dismiss the Workers’ Compensation Court matter, arguing that the court lacked jurisdiction over a state employee’s appeal. The trial judge of the Workers’ Compensation Court denied the motion, concluding that jurisdiction existed based on multiple statutes, including those relating to injured-on-duty payments and the right to appeal denials of accidental disability pensions.The Supreme Court of Rhode Island reviewed the case on certiorari and held that the Workers’ Compensation Court did not have subject matter jurisdiction to hear the deputy sheriff’s appeal. The Court reasoned that the statutory scheme provides for Workers’ Compensation Court jurisdiction only for municipal employees covered under the Optional Retirement Plan, not for state employees like the petitioner, who are covered by the state retirement system. The Supreme Court therefore quashed the trial judge’s order and remanded the case for dismissal due to lack of jurisdiction. View "O'Connell v. Employees' Retirement System of Rhode Island" on Justia Law

The dispute concerns neighboring property owners in South Kingstown, Rhode Island. The plaintiffs purchased their home in 2010, and the defendant purchased the adjoining lot in 2021. The contested area, approximately 1,134.9 square feet, is included in the defendant’s deed, but the plaintiffs asserted that they had used and maintained it as their own for over a decade, engaging in activities such as planting grass and trees, mowing, and storing items. The defendant’s property was vacant until he moved in, and tensions arose after he objected to the plaintiffs’ continued use of the area and eventually erected a fence.Following the defendant’s acquisition and subsequent dispute, the plaintiffs initiated a suit in the Washington County Superior Court, seeking title by adverse possession, acquiescence, or a prescriptive easement. The Superior Court conducted a bench trial, during which testimony was heard from both parties, the developer, and an expert. After trial, the judge found the defendant’s evidence more credible, particularly noting conversations in which the plaintiffs acknowledged the superior title of the prior owner by inquiring about purchasing the disputed property and seeking permission for certain uses. The court determined that the plaintiffs had not demonstrated hostile possession or a recognized boundary for the requisite ten-year period.The Rhode Island Supreme Court reviewed the Superior Court’s findings under a deferential standard, considering whether the lower court’s factual determinations were clearly erroneous. The Supreme Court affirmed the judgment, holding that the plaintiffs failed to establish by clear and convincing evidence the elements of adverse possession, acquiescence, or prescriptive easement, specifically the requirements of hostility and recognition of a boundary. The Supreme Court also found that the trial court’s findings were sufficiently detailed under the applicable procedural rule. The judgment for the defendant was affirmed. View "Blechman v. Woodward" on Justia Law

The plaintiff owned a vacant parcel in Westerly, Rhode Island, and sought to construct a single-family home. To do so, he needed approval from the Department of Environmental Management (DEM) for an onsite wastewater treatment system (OWTS). He applied for a variance from DEM’s regulations, asserting that his proposed system satisfied the general standard for granting variances. However, DEM denied the variance because the property’s water table was at zero inches from the original ground surface, failing to meet a specific regulatory requirement.After DEM’s denial, the plaintiff did not appeal to DEM’s Administrative Adjudication Division (AAD), arguing that such an appeal would be futile since the AAD purportedly lacked discretion to overturn the denial and could not adjudicate constitutional claims. Instead, he filed suit in the Superior Court, seeking declaratory, injunctive, and monetary relief, asserting both as-applied and facial challenges to the OWTS regulations under the Takings, Due Process, and Equal Protection Clauses of the state and federal constitutions. The state moved to dismiss, arguing failure to exhaust administrative remedies and the lack of constitutional violations. The Superior Court granted the state’s motion, finding that the plaintiff failed to exhaust administrative remedies and the futility exception did not apply.On appeal, the Supreme Court of Rhode Island affirmed the Superior Court’s judgment. The Court held that the plaintiff was required to exhaust administrative remedies for his as-applied challenges and that the futility exception did not apply because the AAD had independent authority to grant variances. For the facial constitutional challenge, the Court determined that the complaint failed to state a claim upon which relief could be granted. The judgment dismissing the complaint was affirmed and the matter remanded. View "DiBiccari v. State of Rhode Island" on Justia Law

A man using a cane visited a public beach in Rhode Island and slipped and fell in the bathroom, allegedly due to sand and water on the floor. He suffered several injuries, including a fractured hip, and required medical attention. He filed a negligence lawsuit against the state, claiming the state failed to maintain the bathroom safely, failed to warn of the dangerous condition, and failed to clean the facility. After his death from unrelated causes, his daughter, as administrator of his estate, was substituted as plaintiff.The Rhode Island Superior Court reviewed the case following extensive discovery. The state moved for summary judgment, asserting immunity under the Rhode Island Recreational Use Statute (RUS), which shields landowners from liability for injuries on land open to the public for recreational use unless the injury results from willful or malicious failure to guard or warn against a dangerous condition. The plaintiff argued there were factual issues regarding the state’s knowledge and actions, relying on complaints about cleanliness and state policies. The Superior Court found no evidence the state had specific notice of the hazardous condition or prior similar incidents, and ruled that the RUS applied, granting summary judgment for the state. The court did not reach the issue of the public duty doctrine.The Supreme Court of Rhode Island reviewed the grant of summary judgment de novo. The Court held that the plaintiff failed to present evidence showing that the state willfully or maliciously failed to warn against or remedy a known dangerous condition. There was no genuine issue of material fact, and the state was entitled to immunity under the RUS. Accordingly, the Supreme Court of Rhode Island affirmed the Superior Court’s judgment in favor of the state. View "Estate of Campagnone v. The State of Rhode Island" on Justia Law

The plaintiffs purchased undeveloped property in Westerly, Rhode Island, in 1999. In 2007, they applied to the Rhode Island Department of Environmental Management (DEM) for permission to install an onsite wastewater treatment system (OWTS), a prerequisite for building a residence on their land. DEM denied their application because the groundwater table on the property was only five inches below the surface, while regulations required a minimum of twelve inches. The plaintiffs did not pursue an administrative appeal at that time.In 2020, more than a decade after the denial, the plaintiffs filed suit in Washington County Superior Court, seeking declaratory relief and compensation for an alleged regulatory taking under state and federal law. They also asserted that the regulation violated their rights to equal protection and due process. The state moved to dismiss the action, contending it was time-barred, the plaintiffs failed to exhaust administrative remedies, and they lacked standing. The Superior Court agreed, holding that the claims were barred by the statute of limitations, that administrative remedies had not been exhausted, and that the plaintiffs lacked standing. The court dismissed the case with prejudice.On appeal, the Supreme Court of Rhode Island reviewed whether the lower court’s dismissal was proper. The Court held that the three-year statute of limitations applied to all claims, and the continuing violation doctrine did not toll the limitations period because DEM’s denial of the permit was a discrete act, not a continuing violation. The Court further found the plaintiffs lacked standing for prospective relief because they did not allege an actual or imminent injury, as any future application might not necessarily be denied. The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. View "Majeika v. State of Rhode Island" on Justia Law

Several charitable trusts were established between 1930 and 1969, each naming Memorial Hospital in Pawtucket, Rhode Island, as a beneficiary. The trusts specified the use of funds for purposes such as maintaining “free beds” or supporting general hospital operations. Memorial Hospital operated as an acute care hospital until financial difficulties led to its closure in 2018, at which point it ceased providing inpatient and emergency services. Some outpatient services continued on the campus, but Memorial Hospital was no longer a functioning hospital. Bank of America, as trustee, sought judicial guidance under the cy près doctrine to designate new beneficiaries for the trusts whose purposes could no longer be fulfilled due to the hospital’s closure.Upon review, the Providence County Superior Court found that the closure of Memorial Hospital rendered the trusts’ original purposes impossible, and that each settlor evidenced a general charitable intent. The court conducted a bench trial, considering expert testimony, historical context, and proposals from various organizations, including Kent County Hospital, The Miriam Hospital Foundation, and Progreso Latino. The trustee and several parties proposed a split between The Miriam Hospital Foundation and Progreso Latino, while others argued for Kent County Hospital as the successor beneficiary. The court ultimately rejected both proposals, finding that neither alternative met the settlors’ intent to support actual hospital care.The Supreme Court of Rhode Island reviewed the case on appeal. The Court affirmed the Superior Court’s judgment, holding that the cy près doctrine applied and that The Miriam Hospital, as an acute care hospital offering inpatient and emergency services, was the closest alternative beneficiary to fulfill the original charitable purposes. The Court clarified that the trust proceeds must be used by Miriam Hospital for inpatient and emergency care, consistent with the settlors’ intent. The judgment of the Superior Court was affirmed. View "Bank of America, N.A. v. Neronha" on Justia Law

Dorothy Apostolico, after her husband’s death, deeded a house in Cranston, Rhode Island to her three children, reserving a life estate for herself. The deed did not specify who was responsible for property taxes. Dorothy lived in the house until 2023, after which her son Domenic Apostolico resided there. The property did not produce any income during Dorothy’s life tenancy. Domenic paid property taxes during this time and sought reimbursement from his sister, Deborah Pagliaro, for her share of those taxes. After failed written requests, Domenic initiated a lawsuit seeking contribution and unjust enrichment.The Providence County Superior Court first dismissed Domenic’s original claim for contribution but allowed him to amend his complaint. Domenic then filed an amended complaint seeking Deborah’s share of taxes from 2010 onward. He moved for partial summary judgment on the issue of Deborah’s liability for taxes. Deborah objected and filed a cross-motion for summary judgment. The Superior Court, applying the precedent from Koszela v. Wilcox, 538 A.2d 150 (R.I. 1988), ruled that since the property was not income-producing, the responsibility for taxes fell to the remaindermen. The court granted Domenic’s motion as to liability, denied it as to the specific amount, and final judgment was entered for Domenic in the amount of $38,466.42.On appeal, the Supreme Court of Rhode Island affirmed the Superior Court’s judgment. The Court held that, under Rhode Island law, where a life estate property does not produce income, remaindermen—not the life tenant—are responsible for property taxes, regardless of whether the property is developed or the life tenant resides there. The Court also rejected Deborah’s statutory arguments, finding Koszela controlling and the statutes not in conflict with this rule. View "Apostolico v. Pagliaro" on Justia Law

The case involves a defendant who was charged with several drug-related offenses in two separate incidents, each involving multiple codefendants. The same attorney, David A. Cooper, entered his appearance to represent the defendant in both matters. During bail hearings in the Rhode Island Superior Court, the trial justice expressed concern about a potential conflict of interest because Attorney Cooper had previously represented one of the codefendants in a related matter. The trial justice questioned both the attorney and the defendant about this issue, and the defendant indicated that she understood the situation and wanted to continue with her chosen counsel, expressing her willingness to waive any potential conflict.Despite the defendant’s statements, the Superior Court trial justice removed Attorney Cooper as counsel, citing a “strong potential for conflict,” even though there was no actual conflict at the time. The court’s order was based on the attorney’s prior representation of a codefendant and the possibility that interests might diverge in the future, and a written waiver from the codefendant was obtained, while the defendant’s waiver was made orally in open court.The Supreme Court of Rhode Island reviewed the matter on writs of certiorari. The Supreme Court concluded that, although trial courts have discretion to remove counsel when there is an actual or serious potential conflict of interest, such a removal must be supported by a substantial showing that the likelihood and dimensions of the feared conflict are significant. The Supreme Court held that, in this case, the record did not support a sufficient showing of a substantial potential conflict to justify overriding the defendant’s chosen counsel at that time. Accordingly, the Supreme Court quashed the Superior Court’s orders removing Attorney Cooper as counsel and remanded the case. View "Viera v. State" on Justia Law

Two children were placed in the temporary custody of the Department of Children, Youth, and Families (DCYF) by the Family Court in 2018. The Family Court determined that Newport and Cumberland were responsible municipalities for the children’s education, as they were the residences of the custodial parents. DCYF placed the children in residential treatment facilities where they received general education services, but not special education services.DCYF requested orders from the Commissioner of Elementary and Secondary Education that Newport and Cumberland reimburse DCYF for education costs at the per-pupil special-education rate. The commissioner agreed and ordered the municipalities to pay at that rate. Both municipalities appealed to the Council on Elementary and Secondary Education, which denied their appeals. The municipalities then appealed to the Rhode Island Superior Court under the Administrative Procedures Act. The Superior Court consolidated the cases and found that the statute required the municipalities to pay their share of educational costs, but not at the special-education rate unless special education services were provided. The trial justice also held that, even after statutory amendments removed references to general education, the municipalities were still responsible for the per-pupil general-education rate for children not receiving special education.On review, the Supreme Court of Rhode Island considered whether the municipalities were obligated to pay the general-education rate after the statutory reference to general education was removed. The Court held that the plain language of the statute only requires reimbursement for special education costs and does not obligate municipalities to pay for general education where no special education services are provided. The Supreme Court quashed the decision of the Superior Court. View "Newport School Committee v. Rhode Island Department of Education" on Justia Law

The parties in this case, who were never married but cohabitated and share two minor children, separated in early 2023 after their relationship deteriorated. The plaintiff filed a complaint in the Kent County Family Court seeking joint custody, primary placement of the children, and child support. Shortly after, the defendant filed a separate complaint alleging abuse, resulting in an ex parte temporary protection order and temporary custody for her. Over the following year, the Family Court issued various orders, including appointing a guardian ad litem, scheduling mediation, amending visitation, and addressing discovery issues related to the plaintiff’s income.After several hearings, the Family Court entered four orders on June 25, 2024. These included a visitation order (not challenged on appeal), an order granting primary placement of the children to the defendant, a child-support guideline worksheet setting the plaintiff’s monthly obligation at $1,254, and a handwritten order memorializing child-support details and other arrangements. The plaintiff objected, contending that there was no agreement or sufficient opportunity to present evidence, and that the best interests of the children were not properly considered.The Supreme Court of Rhode Island reviewed the case. It found that the Family Court did not make adequate factual findings regarding the children’s best interests to support the order granting primary placement to the defendant, as required by established precedent. Accordingly, the Supreme Court vacated the disputed portion of the placement order. However, the Court affirmed the child-support guideline worksheet, determining that the plaintiff was bound by his attorney’s actions in signing the worksheet and that no special circumstances warranted overturning it. As the same support amount was memorialized in the handwritten order, the plaintiff’s appeal of that order was deemed moot. The case was remanded to the Family Court for further proceedings. View "Conway v. Orenberg" on Justia Law