Justia Rhode Island Supreme Court Opinion Summaries

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The Supreme Court affirmed the judgment of the superior court entered in favor of Plaintiff that granted Plaintiff's motion for additur, holding that there was no error.In 2013, Plaintiff was involved in an automobile accident. Because she believed she was not fully compensated for the injuries she sustained from the accident, Plaintiff brought this complaint against Allstate Insurance Company, her insurer, seeking underinsured motorist benefits. The jury reached a verdict in favor of Plaintiff, awarding damages in the amount of $22,890. Plaintiff filed a motion for an additur, which the trial justice granted in the amount of $6,000. The Supreme Court affirmed, holding that the trial justice did not abuse his discretion in granting an additur of $6,000. View "Mowry v. Allstate Insurance Co." on Justia Law

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The Supreme Court affirmed the order of the district court denying Movants' motions to intervene in an action commenced by Verizon New England Inc. by way of appeal from a decision of the Tax Administrator for the State of Rhode Island, holding that the trial judge did not err.This appeal arose from Verizon's challenge to a final decision of the tax administrator that upheld an assessment of Verizon's tangible personal property (TPP) tax and denied Verizon's request for a lower assessment and a partial refund. Verizon appealed to the district court. The City of Pawtucket and the City of Cranston (collectively, Movants) moved to intervene as of right, claiming an interest in the TPP tax. The district court denied the motions. The Supreme Court affirmed, holding that the trial judge did not err or abuse his discretion in concluding that Movants failed to demonstrate that their interests were not adequately represented. View "Verizon New England Inc. v. Savage" on Justia Law

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The Supreme Court affirmed the judgment of the superior court convicting Defendant of second-degree sexual assault, breaking and entering, and disorderly conduct following a jury trial, holding that the trial justice did not err in denying Defendant's motion for a new trial.On appeal, Defendant argued that the trial justice erroneously denied his motion for judgment of acquittal on the count alleging disorderly conduct and in denying his motion for new trial on all convicted counts. The Supreme Court disagreed, holding that the trial justice properly exercised its independent judgment, did not err in analyzing the evidence presented, did not overlook or misconceive certain testimony, and articulated adequate reasons for denying Defendant's motion for a new trial based on the weight of the evidence. View "State v. Valdez" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court granting Plaintiffs' claims against Joseph and Lynne Miller and also in favor of the third-party defendant, Assurance Company of America, denying Joseph's third-party claim for indemnification, holding that there was no error.Judgment entered in favor of Plaintiffs and against Joseph and Lynne in the amount of $178,891 and in favor of Assurance on Joseph's third-party claim. Joseph and Lynne appealed, raising three allegations of error. The Supreme Court affirmed, holding (1) the first three allegations of error raised on appeal were waived; and (2) the fourth issue was not properly before the Court. View "Boisse v. Miller" on Justia Law

Posted in: Insurance Law
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The Supreme Court affirmed the judgment of the superior court in favor of the Rhode Island Department of the Attorney General upholding a determination by the Sex Offender Board of Review classifying Petitioner as a Risk Level III sex offender under the Sexual Offender Registration and Community Notification Act, R.I. Gen. Laws 37.1, holding that there was no error.Petitioner pled guilty to three felony counts of distributing, receiving, and possessing child pornography. After Petitioner was released from custody, the Board classified him as a high-level Level III offender. On appeal, Petitioner argued that his sex offender classification was improper because the Board "unreasonably and arbitrarily" overstated his risk level and erred by failing to disclose what material it utilized beyond risk-assessment tools to establish his level of risk. The Supreme Court affirmed, holding that Petitioner failed to show that the Board's classification of him was not in compliance with the law. View "Matteson v. R.I. Department of Attorney General" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of second-degree child molestation following a jury trial, holding that there was no abuse of discretion on the part of the trial justice with respect to the admission of testimony from a physician and from Defendant's brother-in-law.Specifically, the Supreme Court held (1) the trial justice did not commit reversible error by allowing the testimony of a physician testifying as an expert witness with respect to four statements with which Defendant took issue; and (2) Defendant's contentions with respect to the cross-examination of his brother-in-law were waived. View "State v. Benitez" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the district court granting summary judgment in favor of Plaintiffs in their appeal from the order of the state tax administrator denying a refund with respect to a conveyance tax paid pursuant to a memorandum of agreement, holding that Plaintiffs were entitled to judgment as a matter of law.In this dispute surrounding the conveyance tax Plaintiffs paid to expediently transfer a mall and an associate parking garage, the district court concluded that the transfer of interest in a lease entered into by Plaintiffs was not subject to the conveyance tax under R.I. Gen. Laws 44-25-1(a) because of a tax exemption granted through action by the Rhode Island Economic Development Corporation. The district court granted final judgment in favor of Plaintiffs. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment for Plaintiffs. View "Providence Place Group Limited, Partnership v. State ex rel. Division of Taxation" on Justia Law

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The Supreme Court affirmed the judgment of the superior court affirming an order of the probate court admitting the last will and testament of Barbara J. Cardiff, holding that the trial justice did not err in affirming the probate court because the will met the necessary formalities of R.I. Gen. Laws 33-5-5.Before the superior court, Petitioners argued that the will did not conform with the requirements of section 33-5-5 because it was not subscribed by two witnesses, but rather, a witness and a notary public. The trial justice determined that the will was signed by two witness, thus affirming the probate court's order admitting the will to probate. The Supreme Court affirmed, holding that the trial court did not err as to any of the issues raised by Petitioners. View "In re Estate of Barbara J. Cardiff" on Justia Law

Posted in: Trusts & Estates
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The Supreme Court affirmed the superior court's entry of partial final judgment in accordance with Sup. Ct. R. Civ. P. 54(b) and the dismissal for lack of personal jurisdiction of Plaintiff's action under Sup. Ct. R. Civ. P. 12(b)(2) as to certain defendants, holding that the hearing justice did not err.At issue was the superior court's authority to exercise jurisdiction over claims brought against foreign corporate defendants based on a fatal injury to a Rhode Island resident following an accident that occurred outside of Rhode Island. The corporate defendants filed a motion to dismiss for lack of jurisdiction, which the hearing justice granted. Partial final judgment pursuant to Rule 54(b) was entered in favor of the corporate defendants. The Supreme Judicial Court affirmed, holding that the hearing justice (1) did not err in dismissing the claims against the corporate defendants based on a lack of personal jurisdiction; and (2) did not err in denying Plaintiff's request to conduct jurisdictional discovery. View "Martins v. Bridgestone Americas Tire Operations, LLC" on Justia Law

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The Supreme Court affirmed the judgment of the superior court in favor of Plaintiff, Saint Elizabeth Home, and against Defendant, Rebecca Gorham, holding that there was no error.Defendant's mother was admitted to Saint Elizabeth's Home. Three days later, Defendant, acting as her mother's representative, entered into an admission agreement with Plaintiff, agreeing to be personally liable to Plaintiff for all amounts due from her mother. Plaintiff later brought this action alleging breach of the terms of the agreement. The hearing justice granted Plaintiff's motion for summary judgment. The Supreme Court affirmed, holding that the hearing justice properly granted summary judgment for Plaintiff. View "Saint Elizabeth Home v. Gorham" on Justia Law

Posted in: Contracts