Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the superior court confirming an arbitration award in favor of Petitioner, holding that there was no error by the hearing justice in granting the motion to confirm and denying the motion to vacate the award.Respondent filed a negligence action against Petitioner after their automobiles collided. The parties submitted the matter to nonbinding arbitration, and the arbitrator concluded that Respondent failed to satisfy his burden of showing that Petitioner acted negligently. Respondent filed a motion to vacate the arbitration award, and Petitioner filed a separate petition to confirm the arbitration award. The hearing justice confirmed the award. The Supreme Court affirmed, holding that Respondent failed to overcome his burden of defeated the presumption of validity to which an arbitration award was entitled. View "Wiggins v. Pianka" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendants, the individual unit owners of the Goat Island South Condominium (GIS Condominium) and the Goat Island South Condominium Association, Inc. (GISCA), holding that there was no genuine issue of material fact remaining in this case.In his decision, the hearing justice concluded (1) Plaintiff, IDC Clambakes, Inc., had failed to demonstrate that it would be unjust for Defendants to receive any benefit or that it conferred a benefit upon Defendants; and (2) Clambakes' quasi-contract claims were barred by res judicata. The Supreme Court affirmed, holding that Defendants were entitled to judgment as a matter of law because it would be inequitable for Defendants to retain any benefit that may have been conferred on them by Clambakes. View "IDC Clambakes, Inc. v. Carney" on Justia Law

The Supreme Court affirmed the judgment of the superior court entered in favor of Plaintiffs, Charles and Nicole Martin, on their claim for injunctive relief allowing them to access a common driveway for the purpose of entering and existing their property and enjoining Defendants, Glenn and Valerie Wilson, from interfering with such use, holding that the trial justice did not err.Specifically, the Supreme Court held that the trial justice (1) did not err by allowing parol evidence to be admitted; (2) neither overlooked nor misconceived material evidence in finding that Plaintiffs established an implied easement over the disputed section of the common driveway; and (3) did not err by finding that Defendants' counterclaims for declaratory judgment, trespass, and equitable relief were moot. View "Martin v. Wilson" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Plaintiff, the Estate of Michael F. Cassiere, on Plaintiff's claim for distribution of assets held in the Carmen D. Neumann Revocable Trust and on Defendant Joseph Cassiere's counterclaim for breach of fiduciary duty, holding that distribution of the trust was proper.Plaintiff brought this action seeking distribution of the trust's assets and termination of the trust. Defendant filed a counterclaim for breach of fiduciary duty. The trial justice granted summary judgment in favor of Plaintiff on both Plaintiff's claim and Defendant's counterclaim. The Supreme Court affirmed, holding (1) there was no evidence in the record to support the elements of a claim for breach of fiduciary duty; and (2) distribution of the trust was proper. View "Estate of Michael F. Cassiere v. Cassiere" on Justia Law

In this landlord-tenant dispute, the Supreme Court affirmed the order of the superior court dismissing Landlord's complaint as well as Tenants' counterclaims, holding that the superior court properly dismissed the complaint for lack of subject matter jurisdiction.This case arose with respect to conduct that occurred in the context of the parties' landlord-tenant relationship. Landlord filed a complaint in the Providence County Superior Court seeking damages from Tenants. Tenants' answer included a six-count counterclaim. Finding that the superior court lacked jurisdiction over the matter, the hearing justice dismissed all claims and counterclaims. The Supreme Court affirmed, holding that the hearing justice did not err when she dismissed the case for lack of subject matter jurisdiction. View "Marzett v. Letendre" on Justia Law

The Supreme Court affirmed the judgment of conviction and commitment entered in the superior court reflecting the fact that Defendant was found guilty of second-degree murder, holding that the trial justice did not err when she denied Defendant's motion to suppress.Before trial, Defendant filed a motion to videos located on a digital camera, arguing that the detectives who seized the camera improperly expended the scope of the judicially-approved warrant. The trial justice denied the motion. After a jury trial, Defendant was found guilty of second-degree murder and sentenced to life imprisonment. The Supreme Court affirmed, holding that the trial justice did not clearly err in denying the motion to suppress because, in seizing the camera, the police did not exceed the scope of the warrant. View "State v. Depina" on Justia Law

In this partition action, the Supreme Court vacated the judgment of the superior court ruling that Plaintiff's death terminated her interest in a joint tenancy, holding that R.I. Gen. Laws 34-15-12 abrogates the common law right of survivorship in a joint tenancy when an action for partition is pending.Plaintiff filed a partition action requesting that the superior court partition property she owned in a joint tenancy with Defendants. Defendants asserted counterclaims for unjust enrichment and breach of agreement. While the litigation was pending, Plaintiff died. Defendants moved to dismiss the partition action, asserting that Plaintiff's property interest had passed to the remaining joint tenants by operation of law upon Plaintiff's demise. The hearing justice granted the motion. The Supreme Court vacated the judgment, holding that Plaintiff's decease did not abate her action for partition, and therefore, the litigation remained pending. View "Butler v. Gavek" on Justia Law

In this foreclosure action, the Supreme Court affirmed in part and vacated in part the judgment of the superior court, holding that questions of disputed material facts existed regarding Plaintiff's claims for breach of contract and breach of the implied covenant of good faith and fair dealing that could not be resolved on a motion for judgment on the pleadings.Defendants, as mortgagees, caused a foreclosure sale to be conducted for certain property. Plaintiff was the successful bidder. Defendants were prepared to convey title to Plaintiff but when Defendants asserted that Plaintiff was liable for all costs that had accrued with respect to the property, but Plaintiff disputed this liability. Defendants then caused a foreclosure-of-bid letter to be sent to Plaintiff. Plaintiff brought this action alleging four counts. The superior court granted Defendants' motion for judgment on the pleadings. The Supreme Court affirmed the judgment as to the claim under the Unfair Trade Practice and Consumer Protection Act and otherwise vacated the judgment, holding that the district court erred in granting judgment on the pleadings as to the remaining counts. View "Premier Home Restoration, LLC v. Federal National Mortgage Ass'n" on Justia Law

The Supreme Court affirmed Defendant's conviction for six counts of first-degree child molestation sexual assault, three counts of second-degree child molestation sexual assault, and second-degree child abuse, holding that there was no error in the proceedings below.On appeal, Defendant argued among other things, that the trial justice erred in admitting evidence of past bad acts without articulating the special relevance of the evidence in the limiting instructions. The Supreme Court disagreed, holding (1) the trial justice did not overlook or misconceive material evidence in denying Defendant's motion for a new trial; and (2) the trial justice did not err in admitting evidence under Rule 404(b) of the Rhode Island Rules of Evidence because Defendant's objection to the instructions he sought to argue was waived. View "State v. Phillips" on Justia Law

The Supreme Court vacated Defendant's conviction for assault and battery with a dangerous weapon, leaving the scene of an accident resulting in physical injury, reckless driving resulting in physical injury, and violating a no-contact order, holding that the trial justice erred in instructing the jury, resulting in reversible error.Defendant's conviction arose from a bar fight and its aftermath, when Defendant drove his vehicle into two women and then fled the scene. Three counts arose from violations of a no-contact order. On appeal, Defendant argued, among other things, that the trial justice committed reversible error when he instructed the jury that it was entitled to consider whether he was intoxicated at the time of the incident. The Supreme Court agreed and remanded the case for a new trial, holding (1) the trial justice erred when he instructed the jury that it could consider Defendant's intoxication, and the error required reversal of Defendant's convictions; and (2) the trial justice erred in ruling that two separate counts of violating a no-contact order did not merge. View "State v. Narcovich" on Justia Law