Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the family court entered in favor of Plaintiff granting her motion for relief after final judgment and ordering that Defendant comply with the terms of a previously entered consent order, holding that there was no error.When the parties in this case divorced they executed a property settlement agreement that was approved by the family court. Later, a consent order was entered reflecting an agreement between the parties that Defendant's child support obligations would be modified and that the adjustment was in consideration of Defendant agreeing to pay one-half of private and/or Catholic educational expenses, up to and including college. Plaintiff subsequently filed a complaint for relief after final judgment alleging that Defendant refused to pay what he owed for the child's tuition. The family court entered judgment for Plaintiff. The Supreme Court affirmed, holding (1) the family court properly exercised jurisdiction in both entering and enforcing the consent order; and (2) the trial justice properly ruled that Defendant breached his contract to pay for one-half of the child's private university tuition. View "Alessandro v. Caniglia" on Justia Law

In this medical malpractice action, the Supreme Court vacated the order of the superior court granting Plaintiff's motion for a new trial after the jury found that Defendant breached the duty of care owed to the patient in this case, holding that the trial justice erred by replacing the jury's determination with her own.After Patricia Kinney died from complications related to her battle with ovarian cancer, Plaintiff brought this action, asserting that Defendant negligently performed a surgical procedure and post-surgical follow-up. The jury returned a verdict in favor of Plaintiff on the issue of negligence and for Defendant on the issue of proximate cause. The trial justice granted Plaintiff's motion for a new trial, finding that the verdict was against the fair preponderance of the evidence and failed to do substantial justice. The Supreme Court vacated the order, holding that reasonable minds could have come to different conclusions on the question of whether Plaintiff had met her burden of establishing that Defendant's breach was the cause of Kinney's death. View "Joplin v. Cassin" on Justia Law

In this negligence action arising from a slip and fall on an icy sidewalk the Supreme Court affirmed the final judgment of the superior court granting summary judgment in favor of Defendants, holding that the grant of summary judgment was proper.Plaintiff had a reservation at The Old Canteen restaurant. As she approached the restaurant on the public sidewalk she fell and sustained injuries due to the icy condition of the sidewalk in that area. Plaintiff brought this complaint alleging that Defendants - The Old Canteen, Inc. and Canteen Realty, LLC - had a duty to maintain the sidewalk area and its adjacent curbing in a safe and proper condition. Defendants moved for summary judgment arguing that they did not owe Plaintiff a duty with respect to the city sidewalk upon which she fell. The trial justice granted the motion for summary judgment. The Supreme Court affirmed, holding that summary judgment was correctly granted in favor of Defendants. View "Lowney v. Canteen Realty, LLC" on Justia Law

The Supreme Court affirmed the order of the superior court denying Defendants' appeal of a superior court order denying their "motion to vacate" a foreign judgment rendered in New York, which was brought in accordance with the Uniform Enforcement of Foreign Judgments Act, chapter 32 of title 9 of the Rhode Island General Laws, holding that the superior court did not err.In denying Defendants' motion to vacate, the hearing justice concluded that Defendants did not meet their "heavy burden" to overturn the New York default judgment. The Supreme Court affirmed, holding (1) New York law must be applied in addressing the forgery argument presented by Defendants; (2) applying New York law, Defendants failed to meet their burden of rebutting the presumption of due execution accompanying acknowledgements and notarial signatures, and therefore, the subject forum selection clause was valid; and (3) the New York court had personal jurisdiction over Defendants. View "Aspen American Insurance Co. v. East Coast Precast & Rigging LLC" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree murder, discharging a firearm during the commission of a crime of violence, and carrying a firearm without a license, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held that the trial court (1) did not abuse its discretion by denying Defendant's motion to suppress a witness's in-court identification and determining that the witness was a competent witness; (2) properly limited Defendant's cross-examination of two witnesses; and (3) articulated adequate grounds for denying Defendant's motion for a new trial and did not overlook or misconceive material evidence. View "State v. Johnson" on Justia Law

The Supreme Court vacated the judgment of the family court convicting Defendant of cruelty to or neglect of a child and sentencing her to a one-year suspended term of imprisonment, with probation, holding that a new trial was required.On appeal, Defendant argued that the trial justice erred by proceeding with a bench trial without obtaining a knowing, intelligent, and voluntary waiver of Defendant's right to a jury trial and erred in finding habitual neglect in this case. The Supreme Court vacated the judgment below, holding that because there was nothing in the record indicating that the trial justice was assured by Defendant that her waiver of a jury trial was made intelligently and with full knowledge of the consequences of her waiver, the case must be remanded for a new trial. View "State v. Michaud" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant on eight criminal counts related to a robbery and the resulting exchange of gunshots, holding that there was no error in the proceedings below.A jury found Defendant guilty of first-degree robbery, assault with a dangerous weapon, and other convictions. The trial justice ordered Defendant to serve a life sentence as to count one. The Supreme Court affirmed, holding (1) the trial justice did not commit reversible error in refusing to instruct the jury about the withdrawal exception to the initial aggressor rule as it related to the self-defense instruction; and (2) under the circumstances of this case, the trial justice did not abuse his discretion in denying Defendant's motion for a bill of particulars and motion to compel such. View "State v. Isom" on Justia Law

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