Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the superior court in favor of Pascoag Fire District and Pascoag Fire and Rescue Association (the district) and International Association of Firefighters, Local 4908 (the union) (collectively, Defendants) in this action alleging breach of duty of fair representation and breach of contract, holding that there was no error.Plaintiff, a trained firefighter and emergency medical technician who worked for the district, brought this action after he was terminated based on his conduct and performance during a rescue run. Plaintiff began the grievance process between the district and the union, but the union informed Plaintiff that it had decided not to seek arbitration for his grievance. Plaintiff then brought this complaint. The trial court granted judgment in favor of Defendants. The Supreme Court affirmed, holding that there was no error in the trial justice's grant of summary judgment. View "Eddy v. Pascoag Fire District" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of assault with a dangerous weapon and other firearm-related counts stemming from a shooting incident, 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 erred by overlooking or ignoring material evidence that Defendant asserted provided another person with an equal opportunity to commit the charged offenses. The Supreme Court affirmed, holding (1) there was no error in the trial justice's application of the required three-step analysis; and (2) the trial justice did not overlook or misconceive material evidence in denying Defendant's motion for a new trial. View "State v. Rego" on Justia Law

The Supreme Court held that the term "civil action" in Mass. Gen. Laws 27-7-2.2 refers to a judicial proceeding that is commenced by the filing in court of a complaint and all other required documents together with fees.This case involved an accident in which Horace Johnson and Carlton Johnson were seriously injured when Horace was driving. Before any party filed suit, Carlton's counsel sent a letter to Arbella Mutual Insurance Company, which had issued an automobile insurance policy to Horace, demanding a settlement in the amount of the $100,000 policy limit. After Arbella indicated its acceptance of the settlement offer Carlton and his mother (together, Plaintiffs) filed suit. The case was removed to federal district court, which granted summary judgment to Defendants, rejecting Carlton's argument that section 27-7-2.2 applied to the case and rendered Arbella's acceptance of the settlement offer ineffective. On appeal, the First Circuit Court of Appeals certified the instant question to the Supreme Court. The Supreme Court answered that "civil action" in section 27-7-2.2 refers to a judicial proceeding which is commenced by the filing of a complaint and all other required documents together with the fees prescribed by law. View "Johnson v. Johnson" on Justia Law

The Supreme Court affirmed the order of the superior court denying Defendant's motion to vacate entry of default, holding that the hearing justice did not abuse her discretion in denying Defendant's motion.Plaintiff was injured in a motorcycle accident. Plaintiff brought this complaint against Defendant alleging that he was insured by virtue of his contract with Defendant and that the denial of his uninsured motorist claims was unreasonable and made in bad faith. When Defendant failed timely to answer the complaint, default entered against Defendant. Defendant moved to vacate default, arguing that it had never been Plaintiff's insurer. The hearing justice denied the motion, finding that Defendant had not met the applicable standards to vacate default under Rule 55(c) of the Superior Court Rules of Civil Procedure. The Supreme Court affirmed, holding that Defendant failed to show good cause to excuse its failure to plead or defend. View "Ferris v. Progressive Casualty Insurance Co." on Justia Law

The Supreme Court affirmed the decision and judgment of the superior court denying Defendant's motion to correct an illegal sentence pursuant to Rule 35(a) of the Superior Court Rules of Criminal Procedure, holding that Defendant waived his argument on appeal.Defendant pled guilty to several counts related to a gang-related shooting, including first-degree murder, weapons charges, assault, and conspiracy. The trial justice sentenced Defendant to a mandatory term of life imprisonment for first-degree murder, fifty years' imprisonment for offenses ancillary to the shooting, and an additional consecutive ten-year term of imprisonment pursuant to the criminal street gang enhancement statute. Defendant later filed a motion to correct his sentence, asserting that the State had failed to timely notify him of its intention to pursue the criminal street gang sentencing enhancement. The trial justice denied the motion, concluding that Defendant had expressly waived his right to timely notice as part of his agreement with the State. The Supreme Court affirmed, holding that Defendant's waiver of notice under the criminal street gang enhancement statute was valid, and therefore, Defendant's motion to correct sentence was properly denied. View "State v. Briggs" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of simple domestic assault or battery and domestic refusal to relinquish or to damage or to obstruct telephone, holding that there was no error in the trial justice's rulings in this case.On appeal, Defendant argued that the trial court committed reversible error when it impermissibly prevented and restricted his cross-examination of the complaining witness, in violation of the Sixth Amendment. The Supreme Court affirmed, holding that, given the wide discretion afforded to trial justices in limiting the extent of cross-examination, the trial justice did not err in its challenged rulings. View "State v. Garcia" on Justia Law

The Supreme Court affirmed Defendant's judgment of conviction and the denial of his motion for a new trial, holding that the trial justice did not err or abuse her discretion in denying Defendant's motion for a new trial.Following a jury trial, Defendant was convicted of four counts of first-degree child molestation and sexual assault. On appeal, Defendant argued that the trial justice erred by denying his motion for a new trial because the trial justice overlooked material evidence. The Supreme Court affirmed, holding that the trial justice articulated adequate grounds for denying Defendant's motion for a new trial and that the trial justice did not overlook material evidence. View "State v. Vazquez" on Justia Law

The Supreme Court affirmed a superior court judgment of conviction for second-degree sexual assault following a 1993 jury trial and a 2019 superior court judgment adjudicating Defendant a probation violator for his failure to appear for execution of his sentence for that 1993 conviction, holding that there was no error.In 1993, a jury found Defendant guilty of one count of second-degree sexual assault and sentenced him to ten years' imprisonment. Defendant failed to appear for execution of his sentence, and a superior court clerk entered a judgment of conviction and commitment. In 2017, Defendant was arrested and extradited to Rhode Island. In 2018, a second trial justice ordered Defendant to begin serving the unsuspended portion of his original sentence. Thereafter, the State filed a notice of probation violation alleging that Defendant failed to comply with a probation condition when he failed to appear for execution of his sentence. The trial justice declared Defendant a violator of the terms of his probation and sentenced him to an additional three years' incarceration. The Supreme Court affirmed, holding that the trial justice did not err in adjudging Defendant a probation violator for his failure to appear for execution of his sentence. View "State v. Bienaime" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree child molestation sexual assault, holding that the trial justice did not err in denying Defendant's motion for a mistrial.On appeal, Defendant argued that the State posed a question to the complaining witness that was highly prejudicial and violated a pretrial order, and therefore, his motion for a mistrial was improperly denied. The Supreme Court affirmed, holding (1) there was nothing in the record to suggest that the jurors could have been so inflamed by the brief exchange such that they would be unable to examine the evidence in a calm and dispassionate manner; and (2) therefore, the superior court did not err in denying Defendant's motion for a mistrial. View "State v. Barboza" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of voluntary manslaughter, holding that there was no error in the proceedings below.On appeal, Defendant argued that the jury erroneously rejected his claim of self-defense when it returned a verdict of guilty of voluntary manslaughter. The Supreme Court affirmed, holding (1) in its role as fact-finder, the jury was free to reject Defendant's claim of self-defense; and (2) because this issue was never before the trial justice in the context of a motion for a new trial or a motion for judgment of acquittal, the trial justice did not weigh the evidence or pass upon the credibility of witnesses. View "State v. Stevens" on Justia Law