Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the Appellate Division of the Workers' Compensation Court affirming the decree of the trial judge that Petitioner had failed to prove that he sustained a neck injury arising out of and in the course of his employment, holding that legally competent evidence supported the Appellate Division's determination.Before the Supreme Court, Petitioner argued that the trial judge committed reversible error by stating that Dr. Thomas Rocco, M.D. was not qualified to opine on an orthopedic issue because he was a board certified general surgeon, not a board certified orthopedic surgeon, and finding Dr. Rocco's testimony to be inconsistent. The Supreme Court affirmed, holding (1) the Appellate Division did not err in upholding the trial judge's decision to discount Dr. Rocco's testimony; and (2) there was legally competent evidence to support the conclusion of the Appellate Division that Dr. Rocco's testimony was inconsistent. View "Thompson v. Millard Wire Co." on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree robbery and assault with a dangerous weapon in a dwelling with intent to rob, holding that the trial justice did not abuse her discretion in excluding the complaining witness's prior criminal convictions and excluding photographs of bruises on Defendant's torso and supporting testimony from an investigator.Specifically, the Supreme Court held (1) the trial justice did not abuse her discretion in excluding evidence of the complaining witness's prior convictions for resisting arrest and domestic disorderly conduct; and (2) the trial justice did not abuse her discretion in excluding the photographs and supporting testimony because, without further evidence connecting the injuries depicted in the photographs to the altercation with the complaining witness that occurred nearly two weeks earlier, the evidence was inadmissible. View "State v. Lamontagne" on Justia Law

In this action challenging an ordinance passed in 2011 requiring retirees from the City's police and fire departments to enroll in the federal Medicare program upon reaching the age of eligibility instead of continuing to have the City pay for their private health insurance for life the Supreme Court affirmed in part and vacated in part the final judgment of the superior court in favor of the City, holding that the trial judge misconceived the evidence with respect to the health care benefits that Plaintiffs were receiving from the City.Most police or firefighter retirees filed suit challenging the ordinance, and many settled. Some retirees opted out of the settlement and pursued their claims through a bench trial. The trial justice found in favor of the City. The Supreme Court held (1) with respect to Plaintiffs' claims for breach of contract, violation of the Takings Clause, and promissory estoppel, the superior court's judgment was proper; and (2) as to Plaintiffs' Contract Clause claims, the trial justice overlooked or misconceived evidence in several crucial respects. The Court remanded the case with instructions to enter judgment consistent with the provisions pertaining to the Medicare Ordinance as set forth in the final and consent judgment in the lawsuit from which Plaintiffs opted out. View "Andrews v. Lombardi" on Justia Law

In this case challenging the City of Providence's ordinance suspending annual cost-of-living-adjustments (COLAs) for retired members of its police and fire departments until the pension fund achieved a seventy percent funding level the Supreme Court affirmed in part, vacated in part, and reversed in part the trial court judgment in favor of the City, holding that the pension ordinance was unenforceable as to certain plaintiffs.After the City enacted its ordinance in retiree groups and union groups initiated litigation to bar enforcement of the ordinance. Most retirees entered into a settlement that ripened into a consent judgment. Several individuals who opted out of the settlement agreement brought this suit. The trial justice entered judgment for the City. The Supreme Court affirmed in part and vacated in part, holding (1) the superior court correctly entered summary judgment on Plaintiffs' claims under the Takings Clause and for promissory estoppel; (2) with respect to the plaintiffs who were also a party in prior litigation regarding their COLA benefits and who were included in an earlier consent judgment or individual settlement agreement, the pension ordinance was unenforceable; and (3) with respect to Plaintiffs' challenge to the pension ordinance based upon the Contract Clause, the judgment is vacated. View "Andrews v. Lombardi" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant on two counts of first-degree child molestation sexual assault, holding that the trial justice did not err in denying Defendant's motion to suppress statements made to the state police, denying Defendant's motion for a mistrial, and denying Defendant's motion to dismiss counts one and two of the indictment pursuant to Rule 29(b) of the Superior Court Rules of Criminal Procedure.Specifically, the Supreme Court held (1) Defendant's waiver of his Miranda rights was made knowingly, intelligently, and voluntarily, and therefore, the trial justice properly denied Defendant's motion to suppress; (2) the trial justice did not err when she denied Defendant's motion for a mistrial based on an alleged discovery violation by the State; and (3) the trial justice did not err when she credited the complaining witness's testimony in denying Defendant's Rule 29(b) motion to dismiss the first two counts of the indictment relating to first-degree child molestation sexual assault. View "State v. Alvarado" on Justia Law

In this negligence case, the Supreme Court affirmed the judgment of the superior court for Defendants on all counts in Plaintiffs' complaint, holding that Plaintiffs' claims were filed after the three-year statute of limitations had run and were not tolled by the discovery rule, the holding in Heck v. Humphrey, 512 U.S. 477 (1994), the exoneration rule, R.I. Gen. Law 9-1-20, or the doctrine of equitable tolling.Polanco was convicted of assaulting a bar patron with a pool cue. The responding police officer, Michael Camardo, filed no report. After Polanco was convicted, two witnesses swore in affidavits that Polanco was not the assailant. The trial justice granted a new trial, and the State dismissed the case against Polanco, who had been incarcerated for thirty-two months. Polanco and his wife later sued the City of Providence and Camardo, alleging negligence. Defendants moved for summary judgment on the grounds that the complaint was time-barred. Plaintiffs objected, arguing that the discovery rule or equitable tolling should apply. The hearing justice granted summary judgment for Defendants. The Supreme Court affirmed, holding that the complaint was untimely and Plaintiffs' claims were not tolled. View "Polanco v. Lombardi" on Justia Law

The Supreme Court affirmed the order of the family court denying, without prejudice, Mother's motion to intervene, as well as her motion to vacate or, in the alternative, to revoke a guardianship regarding her daughter, holding that, under the circumstances of this case, the hearing justice properly granted the guardianship petition but affirmed without prejudice to Mother filing a motion to revoke the guardianship.A guardianship was filed on behalf of the individuals caring for the child and signed by Father, signifying his consent to the guardianship. The hearing justice granted the guardianship petition. Mother subsequently filed a motion to vacate, otherwise grant relief, or in the alternative, to revoke guardianship, arguing (1) her due process rights were violated because she was never served with process for either the neglect or guardianship petitions, and (2) the guardianship petition was granted in violation of statutory in law because she never gave written consent to the petition. The family court denied the motion. The Supreme Court affirmed, holding (1) despite the lack of formal service of process, the petition was properly granted; and (2) under the circumstances, the hearing justice properly granted the guardianship petition without Mother's consent. View "In re Indiana M." on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Defendant, Pinto's Auto & truck Repair, LLC, in this action alleging that Defendant's repairs to Plaintiff's 2004 Freightliner Columbia were faulty, holding that the hearing justice properly granted summary judgment in Defendant's favor.The hearing justice granted summary judgment for Defendant because Plaintiff did not produce the required expert testimony to demonstrate that there was a genuine issue of material fact in dispute regarding Defendant's allegedly negligent failure to observe industry standard, negligent service and installation, and failure to deliver a properly serviced truck. The Supreme Court affirmed, holding that summary judgment was proper where Plaintiff produced no admissible evidence that Defendant negligently repaired the Freightliner, breached any contract it had with Plaintiff by failing to deliver a properly serviced truck, or alternatively, was unjustly enriched by accepting Plaintiff's money without completing proper repairs. View "Vicente v. Pinto's Auto & Truck Repair, LLC" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Defendants, including a Union and an Employee, and ordering the City of Cranston to arbitrate the Union's grievance filed on behalf of Employee after the trial justice found that Employee, a police officer, remained a member of the bargaining unit, holding that the trial justice did not err.After ending Employee's injured-on-duty benefits, the City terminated his employment. The Union filed a grievance alleging that the City's actions violated the collective bargaining agreement between the Union and the City. The City denied the grievance, and the Union filed a demand for arbitration under the collective bargaining agreement. When a dispute arose about whether an arbitrator should make the determination of whether the dispute was arbitrable the trial justice decided that he should decide that issue because, if a determination was made that Employee was retired, then the Union's grievance would not be arbitrable. The trial justice ruled that Employee had not retired. The Supreme Court affirmed, holding (1) Employee did not retire, and therefore, the Union had standing to pursue a grievance on his behalf and its grievance was substantively arbitrable; and (2) therefore, the trial justice did not err in granting the Union's motion to compel arbitration. View "City of Cranston v. International Brotherhood of Police Officers, Local 301" on Justia Law

The Supreme Court vacated the order of the superior court suppressing the DNA results of a buccal swab taken from Defendant pursuant to a valid search warrant while he was incarcerated, holding that the trial justice erred in suppressing the buccal swab evidence.Three years after the murder of Robert Bullard Defendant was apprehended and taken into custody. A criminal complaint was filed, and Defendant was held without bail at the Adult Correctional Institutions (ACI). Thereafter, a detective obtained search warrants to collect Defendant's DNA at the ACI using a buccal swab. When Defendant refused to comply with the search warrants law enforcement officers used force to obtain the buccal swab. Defendant filed a motion to suppress the DNA evidence, which the trial court granted. The Supreme Court vacated the trial court's order, holding that the use of force was objectively reasonable because the intrusion into Defendant's Fourth Amendment interests was minimal and was far outweighed by countervailing government interests. View "State v. Querido" on Justia Law