Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the superior court granting summary judgment in favor of Defendant, Belltower Acquisitions, LLC, in this personal injury case, holding that the superior court did not err when it granted summary judgment to Defendant.Plaintiff claimed that she fell on a sidewalk adjacent to a Rite Aid Pharmacy in a commercial condominium complex. Rite Aid leased the store from Belltower Acquisitions. Plaintiff sued both Rite Aid, doing business as PJC of Rhode Island, and Belltower Acquisitions but did not name the Belltower Condominium Plaza Association in her lawsuit. The hearing justice granted summary judgment to Belltower Acquisitions based on Plaintiff's failure to comply with R.I. Gen. Laws 34-36.1-3.01. The Supreme Court affirmed, holding that the superior court did not err when it concluded that the certificate requirement in section 34-36.1-3.01 is directory and granting summary judgment to Belltower Acquisitions. View "Rosa v. PJC of Rhode Island, Inc." on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Defendants, in their capacities as the state's general treasurer and the executive director of the Employees' Retirement System of the State of Rhode Island (collectively, ERSRI), holding that the trial court did not err.Plaintiff brought this action asserting a declaratory judgment claim and filing an administrative appeal challenging ERSRI's decision to implement an offset against disability benefits any amount paid or payable under the workers' compensation law and claiming estoppel to prevent recovery of more than $24,000 in overpayments. The trial justice granted partial summary judgment for ERSRI. The Supreme Court affirmed, holding that the trial court did not err in upholding ERSRI's decision to offset workers' compensation benefits paid pursuant to R.I. Gen. Laws 28-33-45 against disability retirement benefits payable to a member of the state retirement system. View "Tiernan v. Magaziner" on Justia Law

The Supreme Court affirmed the judgment of the superior court dismissing Plaintiff's amended complaint in which she sought a writ of mandamus ordering the Town of Smithfield to remove several trees and plants that were planted on the Town's property by neighboring landowners, holding that there was no error.Plaintiff filed this complaint seeking an order directing the Town to remove all of the trees and plants that a Town resident had planted on the Town's property and without the Town's approval. The superior court dismissed the complaint, concluding that the Town did not have a ministerial duty to remove the trees and plants. The Supreme Court affirmed, holding that mandamus did not lie in this case. View "Nerney v. Town of Smithfield" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Plaintiff, in her capacity as Administratrix for the Estate of Lisa Bicknell, following a grant of summary judgment, holding that there was no error.When the Defendant and the decedent were married Lisa participated in a 401(k) retirement plan. Lisa designated her then-husband, Defendant, as a contingent death beneficiary. After the couple divorced, Lisa died without a will and without having changed Defendant's designation as beneficiary of the retirement plan. Plaintiff sought a temporary restraining order to enjoin Defendant from transferring or conveying any portion of the money he had or may receive from the plan, claiming that Defendant had waived all interest in the retirement plan under the parties' property settlement agreement. The trial court ordered that the retirement funds be transferred to Plaintiff. The Supreme Court affirmed, holding that Defendant waived any and all interest in the retirement plan, and no genuine issue of material fact remained in dispute. View "Morgan v. Bicknell" on Justia Law

In these consolidated appeals, the Supreme Court held that Rhode Island's civil death statute, R.I. Gen. Laws 13-61-1, is unconstitutional and in clear contravention of the provisions of R.I. Const. art. I, 5.Plaintiffs, Cody-Allen Zab and Jose R. Rivera, were two inmates serving sentences of life imprisonment. Plaintiff brought this action against Defendants, the Rhode Island Department of Corrections and its director and Global Tel*Link Corporation, asserting that while they were imprisoned they incurred injuries due to Defendants' negligence. The hearing justice concluded that the civil death statute barred Plaintiffs' negligence claims and that Zab's 42 U.S.C. 1983 federal claim failed as a matter of law. The Supreme Court reversed in part, holding that the civil death statute unconstitutionally denied Plaintiffs the right to gain access to the courts. View "Zab v. R.I. Department of Corrections" on Justia Law

The Supreme Court affirmed the judgment of the trial court granting the parties in this case a divorce on the grounds of irreconcilable differences, dividing the parties' marital estate, and awarding joint custody of the parties' child, holding that there was no error.Both parties in this case - Elida Mezini and Leart Mezini - appealed the judgment. The Supreme Court affirmed the decision pending entry of final judgment of the family court, holding (1) there was no error in the trial justice's equitable distribution of the marital property; (2) the trial justice did not abuse his discretion in setting Leart's child support obligations; and (3) as to any remaining issues, the trial court did not err. View "Mezini v. Mezini" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Defendant, Rhode Island Interlocal Risk Management Trust, following the grant of Defendant's motion for summary judgment, holding that there was no error.A few months after the Supreme Court affirmed summary judgment with respect to the underlying claims in Shannahan v. Moreau, 202 A.3d 217 (R.I. 2019) (Shannahan I) Defendant filed a motion for summary judgment in Plaintiffs' action in which Plaintiffs asserted that Defendant wrongfully and in bad faith denied their underlying third-party insurance claims. The trial court granted summary judgment for Defendant. The Supreme Court affirmed, holding that Plaintiffs failed to meet their burden for a bad faith action. View "Shannahan v. Rhode Interlocal Risk Management Trust" on Justia Law

In the medical negligence action, the Supreme Court reversed the order of the superior court denying Plaintiffs' motion for a new trial following a jury verdict in favor of Defendant, holding that the trial justice was clearly wrong in denying Plaintiffs' motion for a new trial.Plaintiffs alleged that Defendant deviated from the appropriate standard of care by failing properly to perform and document assessments of a newborn's intravenous line site. The jury returned a verdict for Defendant. Plaintiffs subsequently filed a motion for a new trial on the grounds that Defendant repeatedly engaged in unfair and prejudicial action before the jury. The trial justice denied the motion. The Supreme Court reversed, holding that the trial justice erred in finding that Defendant's closing argument did not result in prejudice to Plaintiffs. View "Baker v. Women & Infants Hospital of R.I." on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Defendants' motion for summary judgment and granting summary judgment in favor of Plaintiff, Webster Bank, National Association, holding that there was no error in the proceedings below.Plaintiff brought this action for breach of a loan agreement. In the superior court Defendants claimed that the Connecticut statute of limitations should apply because the parties agreed that Connecticut law would govern the loan agreement. The court entered judgment in favor of Plaintiff. On appeal, Defendants argued that the trial justice erred in applying Rhode Island's ten-year statute of limitations to Plaintiff's claim instead of Connecticut's six-year statute of limitations. The Supreme Court affirmed, holding that Rhode Island law controlled in this case. View "Webster Bank, National Ass'n v. Rosenbaum" on Justia Law

The Supreme Court affirmed in part and quashed in part the judgment of the superior court granting Defendant's application for postconviction relief and vacated four criminal convictions for failure to register as a sexual offender, holding that Defendant was no longer required to register as a sex offender in Rhode Island.In 1993, Defendant entered a guilty plea to rape and abuse of a child and was later released. Thereafter, on four separate occasions, the state charged Defendant with failure to register as a sex offender, which led to Defendant's pleas of nolo contendere. Defendant subsequently sought postconviction relief arguing that he was not under an obligation to register as a sex offender at the time of the charged offenses. On remand, the trial court concluded that Defendant had no duty to register as a sex offender and vacated his convictions for failure to register. The Supreme Court quashed the portion of the judgment that vacated Defendant's convictions for his 2009 and 2010 offenses and otherwise affirmed, holding that Defendant was under no obligation to register as a sex offender in Rhode Island. View "Atryzek v. State" on Justia Law