Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the family court denying Mother's motion to relocate with the parties' minor child and vacated the order granting Father's motion to modify child support, holding that the trial justice erred by failing to consider the circumstances concerning the child's needs or Father's ability to pay child support.The parties entered into a property settlement agreement, which was incorporated by reference but not merged into the final decree, that provided for joint custody of the child with physical placement to be with Mother. Father was ordered to pay child support in the amount of $1,471 per month. Mother later filed a motion to relocate with the child to New Jersey. Father objected and filed a motion to modify child support. The trial justice denied Mother's motion to relocate and granted Father's motion to modify. The Supreme Court held (1) the trial justice did not overlook or misconceive material evidence in denying Mother's motion to relocate; and (2) the trial justice's reasoning in granting Father's motion for child support was not proper. View "Andrade v. Andrade" on Justia Law

In this property dispute, the Supreme Court affirmed the judgment of the superior court in favor of Plaintiffs - Middle Creek Farm, LLC; Middlecreek, LLC; and Douglas and Catherine Politi - holding that the hearing justice did not err in partially granting Middle Creek Farm's motion for summary judgment in its declaratory judgment action.Middle Creek Farm brought this action seeking a declaration that Portsmouth Water & Fire District (PWFD) was required to provide water services to subdivision lots. The hearing justice decided that three sub-lots were entitled to water from PWFD and granted summary judgment as to those lots. The Supreme Court affirmed, holding (1) the superior court did not err in deciding that the sub-lots were within the district's coverage for distributing water; and (2) the hearing justice did not err when he denied PWFD's motion to dismiss for failure to join indispensable parties. View "Middle Creek Farm, LLC v. Portsmouth Water & Fire District" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of driving under the influence, holding that Defendant was not entitled to relief as to her allegations of error.On appeal, Defendant argued that the trial justice erred in limiting her cross-examination of the arresting police officer, that the trial justice erroneously denied her motion for a new trial, and that there were pro of law regarding her motion for a new trial. The Supreme Court affirmed, holding (1) the trial justice's limitation of the cross-examination did not constitute an abuse of discretion; (2) there was no error in the trial justice's denial of Defendant's motion for a new trial based on the weight of the evidence; and (3) Defendant's remaining alleged errors of law were waived. View "State v. Ricker" on Justia Law

The Supreme Court affirmed the partial judgment of the order of the superior court granting injunctive relief in favor of Plaintiff, Read's Landscape Construction, Inc., holding that the trial justice did not err.Plaintiff entered into a purchase and sale agreement to buy a one-acre parcel of property from Defendant, 4N Properties, LLC. Plaintiff later filed a complaint alleging that, during the transaction, Defendant committed fraud in the inducement and misrepresentation by altering a right of way and eliminating Plaintiff's ability to use the right of way. The trial justice granted summary judgment in favor of Plaintiff. Plaintiff then moved for injunctive relief. The trial justice found that Plaintiff met the standard for mandatory permanent injunctive relief and ordered Defendant to remove any impediments located on or adjacent to the right of way. The Supreme Court affirmed, holding (1) Plaintiff acquired an easement appurtenant over the right of way; and (2) the trial justice correctly issued a mandatory permanent injunction in favor of Plaintiff. View "Read's Landscape Construction, Inc. v. Town of West Warwick" on Justia Law

The Supreme Court affirmed the decree of the superior court foreclosing Defendants' rights of redemption in property purchased at a tax sale by Plaintiff, holding that there was no error in the proceedings below. As the result of nonpayment of taxes or fees, the City of East Providence sold Defendants' property to Plaintiff at a tax sale. Plaintiff subsequently filed a petition to foreclose Defendants' right of redemption. In their answer, Defendants argued that the tax sale was improper because the mortgagee was not given notice of the outstanding water bill that had triggered the tax sale. The hearing justice entered a final decree foreclosing all rights of redemption and vesting legal and equitable title to the property in Decathlon. The Supreme Court affirmed, holding that neither of Defendants' arguments on appeal satisfied the requirements for application of the constitutional exception to the raise-or-waive rule. View "Decathlon Investments v. Medeiros" on Justia Law

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