Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the superior court convicting Defendant of five counts related to conduct stemming from a drive-by shooting, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) there was no need to reach the merits of Defendant's belatedly raised double jeopardy contention; (2) the trial justice did not err in denying Defendant's motion to suppress an eyewitness identification; (3) the trial justice did not err by summarily denying Defendant's motion to recuse; (4) Defendant was not denied his constitutional right to self-representation; and (5) Defendant's remaining arguments were not properly preserved for appellate review. View "State v. Segrain" on Justia Law

The Supreme Court affirmed the order of the district court committing Respondent to a residential living facility for adults with developmental disabilities, holding that there was no error or abuse of discretion.The Rhode Island Department of Behavioral Healthcare, Developmental Disabilities and Hospitals filed a petition for civil court certification to retain Respondent, a person with developmental disabilities, in a residential facility. The hearing justice found that Respondent was developmentally disabled and ordered that he reside at a group home. The Supreme Court affirmed, holding (1) Respondent's appeal was timely; and (2) Respondent waived his argument that the district court erred in allowing the admission of testimony regarding Respondent's juvenile conviction, his requirement to register as a sex offender, and other uncharged bad acts committed by Respondent. View "In re J.T." on Justia Law

The Supreme Court affirmed the superior court's entry of a judgment of conviction and commitment reflecting the fact that a jury found Defendant guilty of one count of first-degree sexual assault, holding that the trial justice did not abuse its discretion.Specifically, the Supreme Court held (1) the trial justice did not abuse its discretion in allowing an expert witness to testify after the State's late disclosure and fashioning a remedy in reaction to the late disclosure; (2) the trial justice did not abuse its discretion when he admitted the expert testimony because the testimony did not invade the province of the jury; and (3) Defendant's remaining argument was waived. View "State v. Sheridan" on Justia Law

In this action alleging breach of contract and seeking declaratory judgment the Supreme Court affirmed the judgment of the superior court finding in favor of Plaintiffs and the order denying Defendants' motion for a new trial, holding that Defendants were not entitled to relief on their allegations of error.Specifically, the Supreme Court held (1) the trial justice did not err in denying Defendants' motion for a new trial; (2) the trial justice did not abuse his discretion in admitting an audio recording to impeach a witness; (3) even if Defendants' objection to the admission of parol evidence was preserved for review, Defendants' arguments would be unavailing under the Court's parol evidence jurisprudence; and (4) there was no error in the trial justice's determination that there was nothing inherently illegal in the parties' oral agreement. View "Patel v. Patel" on Justia Law

The Supreme Court affirmed the decree of the family court terminating Mother's parental rights to her four minor children pursuant to R.I. Gen. Laws 15-7-7(a)(2)(vii) and 15-7-7(a)(3), holding that this Court will not disturb the trial justice's finding that termination of Mother's parental rights was in the best interests of the children.The trial justice ruled that it was in the best interests of the children that Mother's parental rights be terminated because the child had been in the custody of the Department of Children, Youth and Families (DCYF) for at least twelve months, Mother had been offered services to correct the situation leading to the children's placement, there was no a substantial probability that the children could safely be returned to Mother's care, and that Mother had exhibited behaviors seriously detrimental to the children rendering her future care for the children improbable. The Supreme Court affirmed, holding (1) the trial justice adequately protected Mother's due process rights by ensuring that she was represented at all times; (2) the trial justice did not err when he found that DCYF made reasonable efforts to address the underlying issues leading to the termination of Mother's parental rights; and (3) the termination of Mother's parental rights was in the best interests of the children. View "In re Manuel P." on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment to Defendant, Narragansett Bay Insurance Company (NBIC), in this dispute as to whether Plaintiffs, pursuant to their homeowners insurance policy with NBIC, were entitled to receive a subsequent appraisal of the damage to their property as well as additional compensation for damage incurred, holding that the superior court did not err.Plaintiffs' home, which was insured by NBIC, received water damage stemming from the accumulation of snow on their roof. Plaintiffs submitted a claim to NBIC and received, in return, a check for $14,550. After depositing the check, Plaintiffs later filed a complaint alleging that NBIC had failed to abide by the terms of the homeowners insurance policy and seeking damages for the water damage. The superior court entered summary judgment in favor of NBIC. At issue on appeal was wether Plaintiffs, pursuant to their policy, were entitled to receive a subsequent appraisal of the property damage, along with additional compensation for damage incurred. The Supreme Court affirmed, holding that Plaintiffs' delay in requesting an appraisal was unreasonable, thereby relieving NBIC of its responsibilities under the insurance policy. View "Machado v. Narragansett Bay Insurance Co." on Justia Law

The Supreme Court vacated the partial final judgment of the superior court in favor of Defendants - Visconti, Boren & Campbell Ltd. and Richard Boren - in this legal malpractice action, holding that the summary judgment granted for Defendants on the basis of the determination that Boren did not owe a duty to Plaintiff was in error.In his complaint, Plaintiff alleged that Defendants committed legal malpractice in drafting his antenuptial agreement and in rendering advice related to both the antenuptial and a postnuptial agreement. The trial justice granted summary judgment in favor of Defendants on the narrow issue of Boren's duty in drafting the two agreements. Thereafter, the trial justice granted Plaintiff's motion for entry of partial summary judgment. The Supreme Court vacated the judgment below, holding that the specific question in Plaintiff's motion for partial summary judgment was a question of contract interpretation that was inappropriate for determination on summary judgment. View "DeCurtis v. Visconti, Boren & Campbell Ltd." on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree murder after a jury trial, holding that the trial justice did not err in denying Defendant's motion for a new trial.On appeal, Defendant arguing that the evidence failed to establish beyond a reasonable doubt that the victim's murder was premeditated and that the State failed to meet its burden of disproving voluntary manslaughter. The Supreme Court disagreed, holding that the trial justice did not overlook or misconceive any material evidence and did not err in denying Defendant's motion for a new trial. View "State v. Avila" on Justia Law

The Supreme Court affirmed the order of the family court denying Mother's motion to relocate with the parties' minor child and vacated the order granting Father's motion to modify child support, holding that the trial justice erred by failing to consider the circumstances concerning the child's needs or Father's ability to pay child support.The parties entered into a property settlement agreement, which was incorporated by reference but not merged into the final decree, that provided for joint custody of the child with physical placement to be with Mother. Father was ordered to pay child support in the amount of $1,471 per month. Mother later filed a motion to relocate with the child to New Jersey. Father objected and filed a motion to modify child support. The trial justice denied Mother's motion to relocate and granted Father's motion to modify. The Supreme Court held (1) the trial justice did not overlook or misconceive material evidence in denying Mother's motion to relocate; and (2) the trial justice's reasoning in granting Father's motion for child support was not proper. View "Andrade v. Andrade" on Justia Law

In this property dispute, the Supreme Court affirmed the judgment of the superior court in favor of Plaintiffs - Middle Creek Farm, LLC; Middlecreek, LLC; and Douglas and Catherine Politi - holding that the hearing justice did not err in partially granting Middle Creek Farm's motion for summary judgment in its declaratory judgment action.Middle Creek Farm brought this action seeking a declaration that Portsmouth Water & Fire District (PWFD) was required to provide water services to subdivision lots. The hearing justice decided that three sub-lots were entitled to water from PWFD and granted summary judgment as to those lots. The Supreme Court affirmed, holding (1) the superior court did not err in deciding that the sub-lots were within the district's coverage for distributing water; and (2) the hearing justice did not err when he denied PWFD's motion to dismiss for failure to join indispensable parties. View "Middle Creek Farm, LLC v. Portsmouth Water & Fire District" on Justia Law