Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court vacated the judgment of the superior court granting summary judgment in favor of Defendant in this personal injury case, holding that, contrary to precedent, the hearing justice passed upon an issue that is ordinarily inappropriate for summary judgment.In her complaint, Plaintiff alleged that she slipped and fell on the cement steps leading to the front entrance of Defendant's house and that the absence of handrails was a contributing factor to Plaintiff's fall. The hearing justice, with little explanation, granted summary judgment for Defendant on the grounds that Plaintiff could not indicate the cause of her fall or show that there was proximate cause from the act of Defendant to cause the fall. The Supreme Court vacated the judgment because the hearing justice chose to predicate his grant of summary judgment on his determination that there was no showing of proximate cause, and proximate cause is a question of fact that should not be decided by summary judgment. View "Belmore v. Petterutti" on Justia Law

The Supreme Court quashed the order of the district court that denied Appellant's request for attorneys' fees pursuant to R.I. Gen. Laws 28-44-57(c) after Appellant successfully appealed a denial of unemployment benefits, holding that "appeal" within section 28-44-57(c) encompasses lower court proceedings on the claimant's path to receiving benefits.Appellant in this case successfully challenged the denial of unemployment benefits by the Rhode Island Department of Labor and Training. Appellant filed a petition for counsel fees pursuant to section 28-44-57 for work performed in the appeal to the district court from the Rhode Island Department of Labor and Training (DLT). The district court denied the petition, concluding that Appellant was not entitled to attorneys' fees for work performed by his attorney in the district court. The Supreme Court quashed the district court's order and remanded the case, holding that when an attorney represents an unemployment benefits claimant in an unsuccessful appeal to the district court but subsequently prevails in the Supreme Court, section 28-44-57(c)(2)(iii) entitles the attorney to fees and costs for the proceedings in the district court. View "Beagan v. Rhode Island Department of Labor & Training, Board of Review" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of first-degree child molestation sexual assault and two counts of second-degree child molestation sexual assault, holding that the trial justice did not err in excluding much of a defense witness's proposed testimony.On appeal, Defendant's sole contention was the trial trial justice erred by unfairly limiting the testimony of Jackelyn Rivera, the victim's aunt and a defense witness, in a violation of his constitutional right to present a full and fair defense. The Supreme Court affirmed, holding that, as to the portion of Jackelyn's testimony that would have constituted impermissible hearsay, the trial justice acted appropriately in excluding that testimony. View "State v. Rivera" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of second-degree murder and one count of discharging a firearm during a crime of violence, holding that the trial justice did not err in failing to grant a mistrial and properly denied Defendant's motion for a new trial.On appeal, Defendant argued that the trial justice erred by failing to declare a mistrial and in denying his motion for a new trial. The Supreme Court disagreed, holding (1) the trial justice did not err in failing to grant a mistrial because the grounds for a mistrial that Defendant raised were never articulated before the trial justice; and (2) the trial justice articulated adequate grounds for denying Defendant's motion for a new trial and did not overlook or misconceive material evidence. View "State v. Vidot" on Justia Law

The Supreme Court affirmed the judgment of the superior court dismissing Plaintiff's complaint against Defendants - Brown University and two of its officials - seeking damages and equitable relief arising out of Defendants' response to Plaintiff's sexual assault allegations, holding that the trial court did not err.Plaintiff brought his suit pursuant to the Rhode Island Civil Rights Act, chapter 112 of title 42 of the general laws (RICRA) and article 1, section 2 of the Rhode Island Constitution. The hearing justice granted Defendants' motion to dismiss for failure to state a claim, concluding that issue preclusion foreclosed the claims under RICRA based on a previous decision of the federal courts and that article 1, section 2 did not grant Plaintiff a private right of action. The Supreme Court affirmed, holding that the hearing justice did not err in dismissing Plaintiff's complaint. View "Doe v. Brown University" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of first-degree robbery and other firearm-related offenses, holding that there was no error in the proceedings below.On appeal, Defendant argued that the trial court erred in refusing to instruct the jury on cross-racial identification and that he was denied his right to due process when the trial court denied his motion to dismiss the State's habitual offender notice. The Supreme Court affirmed, holding (1) the trial justice did not err or abuse his discretion in failing to give Defendant's requested instruction regarding cross-racial identifications; and (2) the trial justice did not err in denying Defendant's motion to dismiss the State's habitual offender notice as untimely under R.I. Gen. Laws 12-19-21. View "State v. Hampton-Boyd" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Defendant's motions for judgment as a matter of law and for a new trial and from the judgment in favor of Plaintiffs in this case arising from an assault by one student on another in a high school's hallway, holding that there was no error.Plaintiffs, the assaulted student and his parents, filed an amended complaint alleging that Foster-Glocester Regional School District owed a duty to the student to provide him with a safe learning environment and that the school district failed to do so. A jury found that the school district was negligent and that such negligence was a proximate cause of all three of Plaintiffs' injuries. The Supreme Court affirmed, holding that this Court will not disturb the trial justice's decisions denying the school district's motion for judgment as a matter of law and motion for a new trial. View "Dextraze v. Bernard" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of two counts of second-degree child molestation sexual assault, holding that the trial justice did not err.On appeal, Defendant argued that the trial justice erred by restricting Defendant's right of confrontation and sufficient cross-examination and erred by denying his motion for a new trial. The Supreme Court affirmed, holding (1) it was within the trial justice's discretion to exclude a certain line of questioning on a certain subject; (2) the trial justice did not err by excluding cross-examination with respect to a certain allegation; and (3) the trial justice did not err in denying Defendant's motion for a new trial. View "State v. Chadha" on Justia Law

The Supreme Court vacated the order of the superior court granting the request of Petitioners to appoint a temporary receiver for Respondent, Bard Group, LLC, holding that Petitioners lacked standing to seek the appointment of a receiver, either under statute or as a matter of equity.Respondent owned nine of thirteen condominium units at a certain condominium in Newport, and Petitioners owned the remaining four units. Respondent had a controlling voting share in the condominium association. When the condominium roof began to leak and repairs were not timely made Petitioners filed a petition for the appointment of a receiver for the association. Thereafter, Respondent's mortgage was foreclosed upon. Petitioners then filed a second motion and petition to appoint a receiver in this case, only this time they sought to appoint a receiver for Respondent and not the association. The hearing justice found that Petitioners had standing to pursue the receivership and appointed a temporary receiver for Respondent. The Supreme Court vacated the order, holding that Petitioners lacked standing to seek the appointment of a receiver, and the hearing justice erred in appointing one. View "Epic Enterprises LLC v. 10 Brown & Howard Wharf Condominium Ass'n" on Justia Law

The Supreme Court quashed the decree of the Appellate Division of the Workers' Compensation Court (WCC) awarding attorneys' fees and costs to Petitioner, holding that the WCC's Appellate Division acted in excess of its statutory authority in concluding that R.I. Gen. Laws 45-21.2-9 conferred authority to award attorneys' fees in this case.Petitioner, a firefighter with the City of Woonsocket, sustained a work-related injury and applied for accidental disability retirement (ADR) benefits with Respondent, Municipal Employees' Retirement System of Rhode Island. Respondent denied Petitioner's ADR application, finding that Petitioner had failed to prove that is injury arose out of and in the course of his duties as a firefighter. On appeal, the trial judge granted Petitioner's petition seeking ADR benefits and awarded a counsel fee to Petitioner's counsel. The Appellate Division upheld the fee award and imposed an additional fee for counsel's work before the Appellate Division. The Supreme Court reversed, holding that the General Assembly has not conveyed specific statutory authority upon the WCC to award attorneys' fees and costs in successful ADR appeal claims. View "Koback v. Municipal Employees' Retirement System of R.I." on Justia Law