Justia Rhode Island Supreme Court Opinion Summaries

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

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