Justia Rhode Island Supreme Court Opinion Summaries

In this negligence action, the Supreme Court affirmed the judgment of the superior court in favor of Defendant, the Narragansett Electric Company, holding that a public utility generally owes no common law duty to individual third parties who are allegedly injured, at least in part, as a result of inoperable streetlights.George Lapriocina was walking across a street at an intersection when he was struck by a motor vehicle operated and owned by Defendants. Plaintiff commenced a negligence action alleging that the area where the accident occurred was not properly illuminated at the time of the incident, creating a dangerous condition to pedestrians. The trial justice ultimately concluded that Defendant did not owe a duty of care to George. The Supreme Court affirmed, holding that Narragansett did not owe a legal duty to George, a pedestrian, to maintain the streetlight at issue. View "Laprocina v. Lourie" on Justia Law

The Supreme Court affirmed the judgment of the superior court adjudicating Defendant a probation violator, affirmed the order denying Defendant's motions to dismiss and to reconsider, and affirmed the hearing justice's denial of Defendant's motion to recuse, holding that Defendant's arguments on appeal failed.Specifically, the Supreme Court held (1) given the nature and extend of Defendant's conduct in contributing to the delay in this case, the hearing justice did not err in denying Defendant's motion to dismiss and his motion to reconsider the finding of his probation violation based on the delay between his arrest and the violation hearing; (2) there was sufficient evidence to find that Defendant violated his probation; and (3) the hearing justice acted well within his discretion in sentencing Defendant to six years of his remaining suspended sentence. View "State v. Molina" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Defendants - RISE Prep Mayoral Academy and the City of Woonsocket building inspector and zoning official - and dismissing the City's request for declaratory judgment, injunctive relief, and judicial aid in enforcement, holding that the superior court did not err.The City filed a complaint seeking a declaratory judgment that RISE's operation in a C-2, major commercial district, violated the City's zoning ordinance. The City also sought injunctive relief requesting judicial aid in enforcement of the City's zoning ordinance. The trial justice entered judgment for Defendants, concluding that the operation of RISE in a C-2 zoning district was permitted as a municipal use. The Supreme Court affirmed, holding that because RISE was a public school, its operation was a municipal use permitted in a C-2 zone under the City's zoning ordinance. View "City of Woonsocket v. RISE Prep Mayoral Academy" on Justia Law

The Supreme Court affirmed the decree of the family court terminating Mother's parental rights to her son, holding that Mother's arguments on appeal were unavailing.The trial justice found that was not in the child's best interest to be placed with Mother, that Mother was unfit, and that the child was thriving with foster parents who could offer him permanency. The trial justice then found that it was in the child's best interest that mother's parental rights be terminated. The Supreme Court affirmed, holding (1) the finding of unfitness was supported by clear and convincing, legally competent evidence; (2) the trial justice's finding that reasonable efforts were made to reunify Mother and the child was supported by legally competent evidence; and (3) the trial justice's finding that Mother's termination of parental rights was in the child's best interest was supported by legally competent evidence. View "In re Gelvin B." on Justia Law

The Supreme Court affirmed the order of the family court denying Defendant's motion seeking visitation with his minor daughter, whom he shared with Plaintiff, holding that the family court did not err or abuse its discretion.Upon Defendant's incarceration, Plaintiff filed a complaint for divorce. The family court entered a judgment of divorce awarding Plaintiff sole legal custody and physical placement of the parties' son and daughter and denying visitation rights to Plaintiff. Plaintiff later filed a motion seeking visits with his daughter at the Adult Correctional Institutions. The trial justice denied the motion. The Supreme Court affirmed, holding that the trial justice did not err in denying Defendant's motion to modify visitation. View "Brooks v. Brooks" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of the Estate of Everett Joseph Hopkins in the Estate's action to declare a warranty deed null and void for failure of delivery, holding that the trial justice did not err or abuse her discretion.The trial justice determined that the warranty deed was void for failure of delivery because Everett did not intend to surrender control of and completely divest himself of title to the property. The trial justice further found that the deed was not accepted. The Supreme Court affirmed, holding that the trial justice properly determined that the executed warranty deed was void for failure of delivery and acceptance. View "Estate of Everett Joseph Hopkins v. Hopkins" on Justia Law

The Supreme Court affirmed the order of the family court denying Plaintiff's motion to modify visitation and contact with the two children he shared with Defendant, holding that the family court did not err.In denying Plaintiff's motion, the trial justice found that there was "not a scintilla of evidence" in the record to show that it was in the children's best interests to see or communicate with Plaintiff while he was incarcerated. The Supreme Court affirmed, holding that the family court did not err or abuse his discretion in denying Plaintiff's request to restore visitation and mandate contact with the children where he found no evidence to indicate that it was in the children's best interests to have a relationship with Plaintiff while he was incarcerated. View "Murray v. Jones" on Justia Law

The Supreme Court affirmed the judgments of the family court granting joint custody of the parties' minor child to Mother and Father, with physical placement awarded to Mother, and finding Mother in contempt of a prior visitation order, holding that there was no error.The trial justice issued a written decision and order awarding Mother and Father joint custody, with Mother having physical placement of the child and Father having unsupervised visitation. The trial justice later found Mother in contempt for failure to comply with a prior visitation order. The Supreme Court affirmed, holding that the trial justice did not err in finding Mother in contempt and that Mother's remaining claims of error were unavailing. View "Harris v. Evans" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of the City of Warwick and the State and dismissing this negligence action for personal injuries, holding that the public duty doctrine precluded Plaintiff's claim against the State.Plaintiff was injured when his vehicle struck a pothole. The trial court granted summary judgment in favor of Defendants. Plaintiff appealed, arguing that summary judgment was improperly granted for the State because his claim was not barred by the public doctrine doctrine. The Supreme Court affirmed, holding (1) the trial justice properly found that Plaintiff's reliance on R.I. Gen. Laws 24-8-35 to establish liability was without merit; and (2) the State's failure to repair the pothole in this case was the type of discretionary governmental activity shielded from tort liability under the public duty doctrine. View "Georges v. State" on Justia Law

The Supreme Court affirmed the decision of the trial justice in this case terminating Defendant's marriage to Plaintiff on the grounds of irreconcilable differences, holding that the trial court did not err.After a trial, the trial justice granted both Plaintiff's complaint and Defendant's counterclaim for divorce. The justice awarded the parties joint custody of the children and divided the marital property. Defendant appealed. The Supreme Court affirmed, holding (1) the trial justice did not misconceive evidence and was not clearly wrong in reaching several of his findings; (2) the trial justice did not err in addressing the debts Defendant owed to his parents; and (3) the trial justice did not err in failing to accord Defendant any of the marital appreciation of Plaintiff's premarital accounts. View "Sullivan v. Sullivan" on Justia Law