Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the superior court reversing a decision of the Town of Richmond Zoning Board of Review that denied Plaintiff's application for a special-use permit to construct a solar energy system, holding that there was no error.On appeal, Plaintiff argued that the zoning board's decision was clearly erroneous arbitrary and capricious, and contrary to the law and the evidence. The superior court issued a decision in favor of Plaintiff, concluding that the zoning board decision was affected by an error of law. The Supreme Court affirmed, holding that the trial court did not err in finding that the zoning board decision was affected by error of law. View "Freepoint Solar LLC v. Richmond Zoning Board of Review" on Justia Law

The Supreme Court vacated the judgment of the superior court awarding Plaintiffs final judgment in the amount of $498,309, holding that the superior court erred in denying Plaintiffs' petition to compel purchase in fee.The Providence Public Buildings Authority acquired the development rights of sixty-seven acres of land owned by Plaintiffs. The trial justice denied Plaintiffs' petition for a petition to compel purchase, and the issue of damages proceeded to a jury-waived trial. After the court entered its judgment Plaintiffs appealed, arguing, inter alia, that the trial court erred in denying their petition to compel purchase in fee. The Supreme Court vacated the decision below, holding (1) Plaintiffs' petition to compel purchase in fee was timely filed and, therefore, the doctrine of laches did not apply; and (2) this case is remanded to the superior court with directions to enter an order compelling the taking in fee and for the valuation of a fee-simple interest in the land. View "Mitola v. Providence Public Buildings Authority" on Justia Law

The Supreme Court quashed the decree of the appellate division of the workers' compensation court denying and dismissing Petitioner's petition for surviving-spouse compensation benefits and funeral expenses, holding that the going-and-coming rule did not preclude Petitioner's recovery.At issue was whether the exception to the going-and-coming rule as it was articulated in Branco v. Leviton Manufacturing Company, Inc., 518 A.2d 621 (R.I. 1986) precluded recovery of workers' compensation dependency benefits for the fatal injuries Petitioner's husband sustained while traveling from his employer's facility to a separate parking lot that was leased but not owned by the employer. The trial judge found that Petitioner's claim was not barred by the going-and-coming rule because the Branco exception applied. The appellate division vacated the decision below, finding that the going-and-coming rule barred Petitioner's claim. The Supreme Court quashed the decree below, holding that the Branco exception was applicable to the instant case. View "Phillips v. Enterprise Rent-A-Car Co. of Rhode Island" on Justia Law

The Supreme Court vacated the judgment of the superior court in favor of the Treasurer for the City of Providence (the City) and dismissing Plaintiff's personal injury claim, holding that the trial justice erred in entering judgment in favor of the City.Plaintiff fell into a manhole that was covered with a loose pallet. The jury returned a verdict in favor of Plaintiff and awarded him $87,500 in damages. The City filed a motion for judgment as a matter of law, arguing that the City was immune from liability pursuant to the public duty doctrine. The trial justice granted the motion for judgment as a matter of law. The Supreme Court vacated the judgment below, holding that the trial justice erred in determining that the egregious conduct exception to the public duty doctrine did not apply because the judge usurped the jury's fact-finding function. View "Battaglia v. Lombardi" on Justia Law

The Supreme Court affirmed the order of the superior court granting Defendants' motion to dismiss all electronic, wire, or oral communications obtained through the use of wiretaps and any subsequently-obtained evidence in these consolidated cases, holding that the trial justice did not err.In granting Defendants' motion to suppress, the trial justice found that an associate justice of the superior court had no authority to issue the wiretap orders. The State appealed this ruling and argued, alternatively, that the trial justice erred in concluding that suppression of the evidence derived from the wiretap orders was warranted. The Supreme Court affirmed, holding that the trial court correctly concluded that the associate justice was not vested with the statutory authority to administer and sign the wiretap orders and, therefore, that those orders were in violation of R.I. Gen. Laws 12-5.1, the Interception of Wire and Oral Communications Act. View "State v. McGuire" on Justia Law

The Supreme Court affirmed the judgment of the superior court dismissing Plaintiffs' claims based on lack of standing, holding that there was no error.In 2019, the General Assembly enacted the Reproductive Privacy Act, R.I. Gen. Laws chapter 4.13 of title 23 (RPA), effectively granting a right to abortion in line with Roe v. Wade. 410 U.S. 113 (1973). Plaintiffs initiated this action seeking to halt the passage of House Bill 5125, Substitute B, which later became the RPA. The trial justice denied relief. Plaintiffs then filed a complaint challenging the General Assembly's authority to enact the RPA. The trial court granted Defendants' motion to dismiss for failure to state a claim. The Supreme Court affirmed, holding that Plaintiffs lacked standing to bring their claims. View "Benson v. McKee" on Justia Law

The Supreme Court vacated the decision and order of the superior court declaring Defendant to be in violation of his probation, holding that because Defendant was compliant with court-ordered restitution payments and ran out of time, the remedy could not include incarceration absent a finding of willful violation.Defendant pled nolo contendere to the charge of unlawful appropriation and was ordered to pay restitution. Defendant dutifully paid the amounts set forth in a periodic payment plan but, in anticipation of Defendant's failure to pay restitution in full prior to the expiration of his sentence, the state alleged that Defendant was in violation of his probation. An order subsequently entered declaring Defendant a probation violator. The Supreme Court vacated the decision below, holding that there were other remedies the state could pursue other than incarceration. View "State v. Regan" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree murder, first-degree robbery, and other crimes, holding that Defendant was not entitled to relief on her allegations of error.On appeal, Defendant argued that the trial justice erred in denying her motion to suppress the evidence found at her apartment, denying her motion to suppress the evidence found in her vehicle, and violating her right to confront a witness. The Supreme Court affirmed, holding (1) there was no error in the trial justice's denial of Defendant's motion to suppress the evidence obtained in the apartment based on insufficient probable cause; (2) the trial justice did not clearly err in denying Defendant's request for a Franks hearing; (3) the warrantless seizure of Defendant's vehicle did not violate her rights under either the State or Federal Constitution; and (4) Defendant's Confrontation Clause argument was waived. View "State v. Hudgen" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of possession of child pornography, holding that the State's interesting protecting children from the sexual exploitation portrayed in the images at issue overwhelmingly outweighed Defendant's "expressive interests" in possessing them.Defendant's conviction arise from his possession of computer hard drives or digital storage media containing seventeen computer files of images. The trial justice concluded that six of the images depicted minors engaging in sexually explicit conduct and, based on the six images, convicted Defendant to one count of possession of child pornography. The Supreme Court affirmed, holding that the images depicted unprotected child pornography within the meaning of R.I. Gen. Laws 11-9-1.3. View "State v. Hansen" on Justia Law

The Supreme Court affirmed the order of the family court dismissing Petitioner's verified miscellaneous petition for declaratory judgment, holding that there was no error.This action stemmed from the Department of Children, Youth, and Families' (DCYF) investigation into the maltreatment of Petitioner's biological grandchild, ML. DCYF placed ML with a nonrelative foster family and then terminated Petitioner's son's parental rights to ML. The foster family subsequently adopted ML. Petitioner brought this action seeking a declaration that DCYF violated its statutory obligations by not considering him as a fit and willing relative for ML's placement. The trial justice dismissed the petition after finding that Petitioner lacked standing. The Supreme Court affirmed, holding that Petitioner did not have standing to seek adjudication of his rights to ML when he filed his petition. View "Lacera v. Department of Children, Youth & Families" on Justia Law