Justia Rhode Island Supreme Court Opinion Summaries

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

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

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

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

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