Justia Rhode Island Supreme Court Opinion Summaries

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

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