Justia Rhode Island Supreme Court Opinion Summaries

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

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

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

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

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

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

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