Justia Rhode Island Supreme Court Opinion Summaries

The plaintiff and defendant were married in 1976 and divorced in 1999. Their marital settlement agreement (MSA) stipulated that their marital home would be sold, and the proceeds divided equally. The plaintiff was responsible for household expenses until the sale. The home was not sold until 2019, after the defendant filed a partition action. The defendant then sought specific performance, alleging the plaintiff breached the MSA by preventing repairs and refusing to divide property. The plaintiff counterclaimed, seeking reimbursement for expenses incurred due to the delayed sale and other breaches by the defendant.The Family Court granted in part and denied in part the defendant's motion for summary judgment. It found the MSA clear and unambiguous, except for the clause about splitting the pool bill. The court ruled that the plaintiff was not entitled to reimbursement for expenses related to the marital home, as the MSA did not specify such obligations. The court awarded the defendant the 1982 Mercedes Benz and ordered the division of remaining funds and personal property. The plaintiff was awarded additional amounts for storage costs and attorney fees.The Rhode Island Supreme Court reviewed the case. It affirmed the Family Court's orders, agreeing that the MSA was clear and unambiguous regarding household expenses and that the plaintiff failed to pursue the proper remedy of specific performance for the defendant's alleged breaches. The court also upheld the award of the Mercedes Benz to the defendant and the distribution of funds and personal property. The plaintiff's additional claims for storage costs and contempt were not addressed due to procedural issues and lack of adequate argumentation. View "Jeremiah v. Estate of Jeremiah" on Justia Law

The defendant was convicted of second-degree murder and several firearm offenses after shooting the decedent, Joel Rosario, during a confrontation at a traffic light. The defendant claimed self-defense, stating he felt trapped and threatened by Rosario and others who surrounded his vehicle. The defendant testified that he saw Rosario with a firearm and fired a single shot in fear for his life.The Superior Court found the defendant guilty on all counts and sentenced him to life in prison for second-degree murder, a consecutive life sentence for discharging a firearm during a crime of violence, and additional sentences for other firearm offenses. The defendant appealed, arguing that the trial justice erred by not instructing the jury on the lesser-included offense of voluntary manslaughter, excluding testimony about a threat made by the decedent, excluding testimony about a prior violent altercation, and determining that a social media post depicting the decedent with a firearm was inadmissible.The Rhode Island Supreme Court reviewed the case and found that the trial justice committed reversible error by not instructing the jury on voluntary manslaughter, as there was sufficient evidence to support such a charge. The court also held that the exclusion of the defendant’s grandfather’s testimony about a threat to kill the defendant was reversible error, as it was relevant to the defendant’s state of mind and claim of self-defense. However, the exclusion of testimony about the 2018 pistol-whipping incident was deemed harmless error. The court vacated the judgment of the Superior Court and remanded the case for a new trial on the charge of second-degree murder and the lesser-included offense of manslaughter. View "State v. Esdel" on Justia Law

The case involves a landlord-tenant eviction action where the defendant, Jo-Ann Albanese, was ordered to vacate her apartment by August 1, 2021, by the plaintiff, Red Gate Motel, Inc. Ms. Albanese did not vacate the property and sent a rent payment for August, which was returned uncashed by Red Gate. Red Gate then filed an eviction complaint in District Court, which ruled in favor of Red Gate, awarding possession and damages. Ms. Albanese appealed to the Superior Court.In the Superior Court, Ms. Albanese filed several motions, including a motion to dismiss the eviction action, arguing that Red Gate accepted her rent payment without proper notice. The trial justice deferred ruling on this motion until all evidence was presented. The trial spanned five days, during which Ms. Albanese attempted to introduce a recording to support her retaliatory defense. On the final day of trial, Ms. Albanese was absent due to a medical emergency, and the trial justice rendered a bench decision in her absence, awarding possession and $6,000 in damages to Red Gate. Ms. Albanese's subsequent motions to vacate the judgment and to reconsider were denied by the trial justice.The Rhode Island Supreme Court reviewed the case and found no abuse of discretion by the trial justice. The court noted that Ms. Albanese failed to provide a complete transcript of the lower court proceedings, which limited the review. The trial justice's findings, including the decision to deny the motion to vacate based on Ms. Albanese's purposeful delay, were upheld. The Supreme Court affirmed the judgment and orders of the Superior Court, concluding that Ms. Albanese was given a fair opportunity to present her case and that the trial justice did not overlook or misconceive material evidence. View "Red Gate Motel, Inc. v. Albanese" on Justia Law

The defendant was convicted by a jury in the Superior Court on one count of first-degree child molestation, three counts of second-degree child molestation, and one count of simple assault and battery. The charges stemmed from allegations made by the complaining witness, a minor, who claimed that the defendant, her mother's boyfriend, had sexually abused her over several years. The witness wrote a letter to her mother detailing the abuse and later provided a handwritten statement to the police.In the Superior Court, the trial justice admitted the letter as nonhearsay under Rule 801(d)(1)(B) of the Rhode Island Rules of Evidence, reasoning it was offered to rebut an implied charge of recent fabrication. The trial justice also admitted the handwritten statement to the police as an excited utterance under Rule 803(2). The defendant was sentenced to life imprisonment for the first-degree child molestation count, thirty years for each of the second-degree child molestation counts, and one year for the simple assault and battery count, all to run concurrently. The defendant appealed, arguing that the trial justice erred in admitting the out-of-court statements and excluding video evidence of the witness's demeanor at the police station.The Rhode Island Supreme Court reviewed the case and found that the trial justice erred in admitting the letter as nonhearsay because the defense did not allege recent fabrication. The court also determined that the handwritten statement did not qualify as an excited utterance since it was made months after the alleged events. Additionally, the court held that the exclusion of the video evidence was within the trial justice's discretion. Concluding that the erroneous admission of the statements was not harmless and likely contributed to the conviction, the Supreme Court vacated the judgment of conviction and remanded the case for a new trial. View "State v. Aponte" on Justia Law

The defendant, Jason Ortiz, was charged with several criminal counts, including carrying a pistol without a license, domestic assault, resisting arrest, and disorderly conduct. The charges stemmed from an incident in which Ortiz was apprehended by police after a domestic dispute. The police found a pistol in the vicinity of Ortiz's arrest, and DNA evidence linked Ortiz to the weapon. Ortiz was nineteen years old and a resident of Massachusetts at the time of his arrest.In the Superior Court for Providence County, Ortiz filed a motion to dismiss the charge of carrying a pistol without a license, arguing that the Rhode Island statute requiring a license to carry a pistol violated his Second Amendment rights. The state objected, arguing that Ortiz lacked standing to challenge the statute because he had never applied for a license and therefore had not been denied one. The trial justice denied Ortiz's motion to dismiss, finding that Ortiz lacked standing to challenge the statute and that the statute was reasonably adopted to address the government's interest in reducing gun violence. After a bench trial, Ortiz was found guilty of carrying a pistol without a license and sentenced to five years imprisonment, with eighteen months to serve and the balance of the sentence suspended, with probation.On appeal to the Supreme Court of Rhode Island, Ortiz argued that the trial justice erred in denying his motion to dismiss. He contended that the licensing statute violated his Second Amendment rights and that he had standing to challenge the statute because he was being punished for violating it. The state argued that Ortiz lacked standing to challenge the statute because he had not applied for a license. The Supreme Court affirmed the judgment of the Superior Court, holding that Ortiz lacked standing to challenge the licensing statute because he had not applied for a license and would not have qualified for one had he applied due to his age and residency. The court declined to reach Ortiz's arguments regarding the constitutionality of the licensing statute. View "State v. Ortiz" on Justia Law

The case revolves around a plaintiff, Carol Allen, who slipped and fell on the steps of Newport City Hall during a winter storm, resulting in severe injuries. Allen alleged that the city and its employees were negligent in failing to properly treat the stairs for adverse weather conditions. The case was heard in the Superior Court, where the trial justice ruled in favor of Allen, finding that the city and its employees had a duty to clear the steps of snow and ice, even during an ongoing storm, due to "unusual circumstances."The city and its employees appealed the decision to the Supreme Court of Rhode Island. They argued that the trial justice erred in not applying the "Connecticut Rule," which states that a property owner's duty to clear snow and ice does not arise until a reasonable time after a storm has ended. The city argued that the storm was ongoing at the time of Allen's fall, and therefore, they did not owe her a duty to clear the steps.The Supreme Court of Rhode Island agreed with the city and its employees. The court found that the trial justice had erred in applying the "unusual circumstances" exception to the Connecticut Rule. The court clarified that "unusual circumstances" exist when a property owner's actions exacerbate the inherent risk of traveling during a storm, not when the owner fails to alleviate the danger. In this case, the city and its employees did not engage in any behavior that increased the risk to Allen. Therefore, the court vacated the judgments of the Superior Court and remanded for entry of judgment in favor of the city and its employees. View "Allen v. Sitrin" on Justia Law

In early 2020, Josephson, LLC, doing business as The Moinian Group (Moinian), filed a lawsuit against its insurance company, Affiliated FM Insurance Company (AFM), seeking coverage for losses sustained due to the COVID-19 pandemic. Moinian argued that the presence of COVID-19 at its insured properties constituted "physical loss or damage" under its insurance policy. The trial justice, however, determined that the presence of COVID-19 alone did not constitute "physical loss or damage" sufficient to implicate the coverage provisions. The trial justice also concluded that the Contamination Exclusion in the insurance policy unambiguously barred coverage because contamination, such as COVID-19, was expressly excluded under the terms of the policy.The Superior Court granted AFM's motion for partial summary judgment and denied Moinian's motion for partial summary judgment. The court determined that the presence of COVID-19 at Moinian's insured properties did not constitute "physical loss or damage" under the terms of the policy. The court also found that the Contamination Exclusion in the policy unambiguously applied to bar Moinian's claim. Moinian appealed the decision.The Supreme Court of Rhode Island affirmed the trial justice's determination. The court agreed with the lower court's interpretation of the Contamination Exclusion in the insurance policy. The court concluded that the exclusion for "contamination" was intended to limit coverage for a "type of risk," not a "type of loss." Therefore, the court held that Moinian's losses due to the COVID-19 pandemic were not covered under the insurance policy. View "Josephson v. Affiliated FM Insurance Company" on Justia Law

The plaintiff, Gail M. McCormick, filed a personal injury lawsuit against Narragansett Improvement Company, Inc. (NICO) for injuries she sustained in a motorcycle accident on May 29, 2010. McCormick alleged that she lost control of her motorcycle due to unguarded manhole covers on a road in Cranston, Rhode Island, which NICO was contracted to repair. NICO failed to respond to the lawsuit, and a default judgment was entered against them on November 18, 2011. However, NICO later sought to vacate the default judgment, arguing that they had not begun repairs on the road until after the accident occurred.The Superior Court granted NICO's motion to vacate the default judgment. The case proceeded to a seven-day jury trial in March 2022, which resulted in a verdict in favor of NICO. McCormick subsequently filed a motion for a new trial, which was denied by the trial justice.McCormick appealed to the Supreme Court of Rhode Island, arguing that the Superior Court erred in vacating the default judgment and in denying her motion for a new trial. The Supreme Court found that the Superior Court had abused its discretion in vacating the default judgment without requiring NICO to provide evidence explaining their failure to respond to the lawsuit. The Supreme Court therefore vacated the judgment of the Superior Court and remanded the case for a hearing on the assessment of damages. View "McCormick v. Narragansett Improvement Company, Inc." on Justia Law

The plaintiff, Xavier T. Vidot, an inmate, filed a complaint against the Rhode Island Department of Corrections (RIDOC) and its officials, alleging that they failed to provide inmates with a daily minimum of 8.5 hours outside their cells, in violation of RIDOC's internal policy and a state statute. The plaintiff sought a writ of mandamus, a declaration of violation, and a permanent injunction.The defendants moved to dismiss the complaint, arguing that RIDOC's internal policies do not establish a private cause of action for inmates and that the application of these policies involves discretionary decisions. The plaintiff responded, asserting that the defendants had a ministerial legal duty to operate in accordance with RIDOC's policy and that the statute does not afford the defendants any discretion except that which is allowed by internal policies.The Superior Court granted the defendants' motion to dismiss, reasoning that the policies governing these issues are internal and discretionary, as they are not codified in the statute. The plaintiff appealed this decision.The Supreme Court of Rhode Island affirmed the Superior Court's decision. The court found that the statute outlining the duties of the director of the Department of Corrections clearly bestows upon the director a great deal of discretion in the exercise of his or her duties. The court also found that both the previous and amended versions of RIDOC's policy contemplate that RIDOC must exercise its discretion in "exigent circumstances," in the case of "emergencies," or in the event of "overriding conditions"—all for the purpose of maintaining a "safe and orderly operation of the facility." Therefore, the court concluded that the hearing justice did not err in denying relief in the form of a writ of mandamus and in granting the motion to dismiss. View "Vidot v. Salisbury" on Justia Law

The case involves North Farm Home Owners Association, Inc. (North Farm) and the Bristol County Water Authority (BCWA). North Farm, a multi-building condominium complex in Bristol, Rhode Island, had granted several easements to BCWA, a public utility responsible for providing water to residential and commercial customers in Bristol County. From 1975 to 1995, BCWA measured water service to each condominium unit individually. However, between 1993 and 1995, representatives of the parties discussed converting the individual meter system to a centralized, master meter system. This correspondence is at the heart of the dispute.The Superior Court entered partial summary judgment in favor of BCWA on counts three and four of North Farm's third amended complaint. North Farm appealed, arguing that a valid contract was formed through their 1993–1995 correspondence, that the hearing justice ignored allegations that the 2019 pass-through rate was illegal, and that the hearing justice denied North Farm’s motion to amend without a finding of prejudice.The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. The court found that the 1993–1995 correspondence did not establish the existence of a contract as a matter of law. The court held that the letters did not show the parties’ mutual assent to the material contract terms by means of offer and acceptance. The court also found that North Farm failed to produce sufficient evidence that a valid contract for the material terms existed. Therefore, the hearing justice’s grant of summary judgment on count three of the third amended complaint was proper. The court also affirmed the hearing justice's grant of summary judgment on count four, as North Farm did not properly plead any basis for granting injunctive or compensatory relief due to BCWA’s purported unlawful discrimination. View "North Farm Home Owners Association, Inc. v. Bristol County Water Authority" on Justia Law