Justia Rhode Island Supreme Court Opinion Summaries

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

The Supreme Court reversed the decision of the superior court granting summary judgment in favor of Appellee on the basis that Appellant failed to perfect her probate appeal under R.I. Gen. Laws 33-23-1, holding that Appellant perfected her probate appeal.Appellant, the surviving spouse of the decedent, filed a claim of appeal after the decedent's will, which named Appellee as executrix and left his law firm assets to her, was admitted to probate. The hearing justice granted summary judgment for Appellee, concluding that Appellant did not comply with the statutory requirements of section 33-23-1. The Supreme Court reversed and remanded the case, holding that there was competent evidence proving the existence of a disputed issue of material fact. View "Estate of John P. Garan" on Justia Law

The Supreme Court affirmed the decree of the family court terminating Father's parental rights to his daughter, holding that the family court did not abuse its discretion.After a termination trial, the trial justice terminated Father's parental rights to his daughter, concluding that Father was unfit to parent his child due to his failure to address his mental health and substance abuse issues and his refusal to attend counseling and that it was in the child's best interest that Father's parental rights be terminated. The Supreme Court affirmed, holding that the trial justice was not clearly wrong in concluding that Father was unfit as a parent and that there was no substantial probability that the child could be placed in Father's care within a reasonable period of time. View "In re Elana W." on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the superior court revoking Appellant's pension benefits and denying his request for return of his retirement contributions paid into the Employees' Retirement System of the State of Rhode Island (ERSRI), holding that the superior court erred in part.The superior court revoked Appellant's pension benefits, denied his request for return of his retirement contributions paid to the ERSRI, and ordered that retirement payments made to his spouse be applied towards his restitution obligations. The Supreme Court vacated the judgment in part, holding that the trial justice (1) did not err in revoking Defendant's pension benefits; (2) did not err in declaring that Appellant's spouse was an innocent spouse and awarding pension payments; (3) erred in directing the spouse to pay her payments as an innocent spouse towards Defendant's restitution obligations; and (4) vacated the portion of the judgment declining to apply Appellant's pension contributions to his restitution obligations. View "Retirement Board of Employees' Retirement System of State of R.I. v. Randall" on Justia Law

The Supreme Court affirmed in part and quashed in part the judgment of the superior court affirming a decision of the Town of Charlestown Zoning Board of Review denying a special-use permit and a dimensional variance, holding that there was insufficient evidence to support the denial of the special-use permit.New Castle Realty Company applied to the zoning board for a special-use permit and a dimensional variance to build a house and install a septic system on a preexisting nonconforming lot. The zoning board denied both requests. The Supreme Court affirmed in part and quashed in part the superior court's judgment, holding (1) substantial evidence did not exist in the record to support either the zoning board's decision to deny the special-use permit or the trial justice's ruling affirming the denial of the special-use permit; and (2) the trial justice correctly concluded that certain testimony was fatal to New Castle's request for a dimensional variance. View "New Castle Realty Co. v. Dreczko" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendant, as trustee of the Trust of Anna H. Blankstein, and dismissing Plaintiff's complaint for an accounting pursuant to R.I. Gen. Laws 18-13-15(b), holding that Plaintiff was not entitled to relief.Plaintiff, the beneficiary of the Trust of Anna H. Blankstein, brought this action requesting an accounting pursuant to the Rhode Island Uniform Custodial Trust Act (RIUCTA). Defendant moved for summary judgment, arguing that, by its terms, the trust was not a custodial trust, and therefore, Plaintiff was not entitled to an accounting of the trust. The trial justice granted summary judgment in favor of Defendant. The Supreme Court affirmed, holding (1) Blankstein did not create a custodial trust because the trust did not meet the requirements set forth in RIUCTA; and (2) Plaintiff did not have standing as the administrator of the estate to request an accounting. View "Shorr v. Harris" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Defendant's renewed motion for judgment as a matter of law or, in the alternative, a motion for a new trial, holding that the trial justice did not err in denying the motions.A dispute over certain real property resulted in litigation and a jury trial. Plaintiff bought an eight-count amended complaint against Defendant. The jury was instructed to consider only Plaintiff's promissory estoppel and unjust enrichment claims, and the jury rendered a verdict in favor of Plaintiff on those counts. The Supreme Court affirmed, holding that Defendant was not entitled to judgment as a matter of law or a new trial as to the promissory estoppel and unjust enrichment claims. View "Salvatore v. Palangio" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of second-degree murder, receiving stolen goods, conspiracy, operating a vehicle on a suspended license, and carrying a knife greater than three inches in length, holding that there was no error.Specifically, the Supreme Court held (1) the trial justice did not err in denying Defendant's motion to suppress the fruits of his third interrogation; (2) the trial justice did not err by declining to redact certain prejudicial statements Defendant made while he was alone in the interrogation room; (3) Defendant's argument that his detention was extensive and that he was denied prescription medication during detention was waived; and (4) Defendant's argument that the trial justice abused his discretion by failing to suppress a witness's out-of-court identification was also waived. View "State v. Baribault" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of first-degree sexual assault and three counts of second-degree child molestation after a jury trial, holding that there was no error in the proceedings below.On appeal, Defendant argued that the trial justice clearly erred in denying his motion for a new trial because the justice overlooked and misconstrued material evidence and the weight of the evidence did not support the verdict. The Supreme Court disagreed and affirmed, holding that there was no reversible error in the trial justice's analysis of the motion for a new trial or in his decision denying the motion. View "State v. Acosta" on Justia Law