Justia Rhode Island Supreme Court Opinion Summaries

In the early morning of August 11, 2021, Officer Robert Savage of the Providence Police Department responded to a 911 call at a home on Canton Street, where he encountered gunfire from Luis Roman, who was heavily intoxicated and fired numerous shots from an AR-15 rifle at the officer's vehicle. The call was made by Roman's girlfriend, Stephanie Perez, after Roman physically assaulted her. Roman fled but was later arrested at his mother's house. He was indicted on ten charges, including assault with intent to murder and possession of a firearm by a person previously convicted of a crime of violence.Roman pled guilty to eight of the ten charges, acknowledging his status as a habitual offender and probation violator. The Superior Court sentenced him to seventy years, with thirty years to serve, including ten nonparolable years. Roman filed a motion to reduce his sentence under Rule 35, arguing that the sentencing justice did not adequately consider his diminished capacity and other mitigating factors. The motion was denied, with the court noting Roman's waiver of his right to file such a motion due to his guilty plea and finding the sentence appropriate given the circumstances.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's order. The court held that the sentencing justice acted within his discretion, considering Roman's violent criminal history and the severity of his actions. The court found no due process violation in the sentencing justice's consideration of Roman's alleged statement about preferring a shootout with police over returning to prison. The sentence was deemed justified and not grossly disparate from other sentences for similar offenses. View "State v. Roman" on Justia Law

A reporter for The Providence Journal submitted an Access to Public Records Act (APRA) request to the Office of Governor Daniel J. McKee, seeking a list of individuals who received preferred license plates. The Governor’s Office denied the request, citing the federal Driver’s Privacy Protection Act (DPPA) and state law, which protect such information from disclosure. The Providence Journal argued that the DPPA did not apply because the records were maintained by the Governor’s Office, not the Department of Motor Vehicles (DMV).The Rhode Island Office of the Attorney General upheld the Governor’s Office’s denial, stating that the Governor’s Office effectively acts as an agent of the DMV in this context. LMG Rhode Island Holdings, Inc., the publisher of The Providence Journal, then filed a complaint for declaratory and injunctive relief in the Superior Court, arguing that the denial violated APRA. The Superior Court dismissed the complaint, agreeing with the Attorney General that the DPPA applied to the Governor’s Office in this context and that the requested information was exempt from disclosure under APRA.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court’s judgment. The Court held that the DPPA applies to the Governor’s Office when it processes preferred plate applications, as it acts as an agent of the DMV. The Court also concluded that the information requested was protected by the DPPA, as it pertains to motor vehicle registration records. Consequently, the denial of the APRA request was lawful.Additionally, the Supreme Court affirmed the Superior Court’s denial of the Governor’s Office’s motion for attorneys’ fees. The Court found that the plaintiff’s case had some grounding in existing law and was not frivolous, thus not warranting an award of attorneys’ fees. View "LMG Rhode Island Holdings, Inc. v. Office of Governor McKee" on Justia Law

Cashman Equipment Corporation, Inc. (Cashman) was contracted by Cardi Corporation, Inc. (Cardi) to construct marine cofferdams for the Sakonnet River Bridge project. Cashman then subcontracted Specialty Diving Services, Inc. (SDS) to perform underwater aspects of the cofferdam installation. Cardi identified deficiencies in the cofferdams and sought to hold Cashman responsible. Cashman believed it had fulfilled its contractual obligations and sued Cardi for breach of contract, unjust enrichment, and quantum meruit. Cardi counterclaimed, alleging deficiencies in Cashman's construction. Cashman later added SDS as a defendant, claiming breach of contract and seeking indemnity and contribution.The Superior Court denied SDS's motion for summary judgment, finding genuine disputes of material fact. The case proceeded to a jury-waived trial, after which SDS moved for judgment as a matter of law. The trial justice granted SDS's motion, finding Cashman failed to establish that SDS breached any obligations. SDS then moved for attorneys' fees, which the trial justice granted, finding Cashman's claims were unsupported by evidence and lacked justiciable issues of fact or law. The trial justice ordered mediation over attorneys' fees, resulting in a stipulated amount of $224,671.14, excluding prejudgment interest.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's amended judgment. The Supreme Court held that the trial justice did not err in granting judgment as a matter of law, as Cashman failed to provide specific evidence of justiciable issues of fact. The Court also upheld the award of attorneys' fees, finding no abuse of discretion. Additionally, the Court determined that the attorneys' fees were not barred by the Bankruptcy Code, as they arose post-confirmation and were not contingent claims. View "Cashman Equipment Corporation, Inc. v. Cardi Corporation, Inc." on Justia Law

Marilyn Wilson and Milton Wilson were married in 1980, and Milton was employed as a police officer. They divorced in 1998, and their property settlement agreement stated that Marilyn would be the irrevocable beneficiary of Milton's survivor pension benefits. Milton later married Diane Wilson in 2007 and passed away in 2020. After his death, Marilyn sought survivor benefits from the City of Providence, which were being paid to Diane.The Family Court declined to rule on Marilyn's motion to compel the city to pay her the benefits, leading her to file a suit in the Superior Court. The Superior Court granted summary judgment in favor of Diane, ruling that she was the surviving spouse entitled to the benefits under Rhode Island General Laws § 45-21.3-1 and the Providence Code § 17-189(m)(6).The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's judgment. The Court held that the terms "surviving spouse" and "dependent spouse" in the statute and ordinance refer to the person lawfully married to the retiree at the time of death. The Court found that the property settlement agreement between Marilyn and Milton, which was incorporated but not merged into the final divorce judgment, could not override the statutory provisions. Therefore, Diane, as Milton's spouse at the time of his death, was entitled to the survivor benefits. View "Wilson v. The City of Providence" on Justia Law

On June 26, 2018, a fatal shooting occurred near 100 Lowell Avenue in Providence, Rhode Island, resulting in the death of David Page. The investigation into the murder led to the arrest of Chandanoeuth Hay and his codefendant, Jaythan Hang. Hay was charged with ten counts, including first-degree murder, conspiracy, assault with a dangerous weapon, and firearm-related offenses. A grand jury indicted Hay on December 9, 2019. During the trial, the prosecution presented evidence linking Hay to the crime, including testimony from a cooperating witness, Kennedy Terrero, who described gang affiliations and prior violent incidents involving Hay.The Providence County Superior Court held pretrial hearings on several motions filed by Hay, including motions to suppress evidence and exclude certain testimonies and photographs. The trial justice denied these motions, allowing the evidence to be presented at trial. Hay was subsequently found guilty on all counts by a jury on October 6, 2022. Hay filed motions for a new trial and judgment of acquittal, which were denied by the trial justice. On February 13, 2023, Hay was sentenced to multiple consecutive and concurrent prison terms, including two life sentences.The Rhode Island Supreme Court reviewed Hay's appeal, which raised four grounds for reversal: the admission of lay opinion testimony by a police sergeant, the denial of a Franks hearing, the admission of testimony about unrelated shootings, and the admission of certain photographs. The Supreme Court affirmed the Superior Court's judgment, finding no abuse of discretion in the trial justice's rulings. The Court held that the lay opinion testimony was properly admitted, the denial of the Franks hearing was justified, the Rule 404(b) evidence was relevant and not overly prejudicial, and the photographs were admissible to demonstrate Hay's relationship with Terrero and access to firearms. View "State v. Hay" on Justia Law

The plaintiff, William Boggs, was injured on August 9, 2016, while transferring liquid asphalt from a tanker truck to a distribution truck in Framingham, Massachusetts. He was sprayed with liquid asphalt, resulting in burns and permanent injuries. Boggs was employed by All States Asphalt, Inc. (All States), which accepted his workers' compensation claim. Boggs filed a complaint against Johnston Asphalt, LLC, alleging negligence in maintaining the truck that caused his injuries.The Kent County Superior Court granted summary judgment in favor of Johnston Asphalt on February 27, 2024. The court found no genuine issues of material fact and concluded that Johnston Asphalt owed no duty to Boggs. The court noted that the truck was owned and maintained by All States, and the only person who worked on the truck was an All States employee, Michael Kelly. The court also rejected Boggs' argument to pierce the corporate veil, finding no evidence that Johnston Asphalt and All States were not separate entities.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's judgment. The Supreme Court held that Boggs failed to present competent evidence to demonstrate a genuine issue of material fact regarding Johnston Asphalt's duty of care. The court found that the single piece of mail addressed to Kelly at Johnston Asphalt's address was insufficient to establish that Kelly was an employee of Johnston Asphalt. The court also upheld the lower court's decision not to pierce the corporate veil, as Boggs did not meet the burden of proof required to disregard the corporate entity. View "Boggs v. Johnston Asphalt, LLC" on Justia Law

The plaintiffs, Boyang Song and Travis McCune, own a unit at The 903 condominium complex in Providence, Rhode Island. They filed a lawsuit against Evan Lemoine and Stephen Rodio, the president and secretary of The 903 Condominium Owner’s Association, respectively. The dispute arose when the defendants failed to include the plaintiffs' specific agenda items in a special-meeting petition regarding gas metering and billing issues at the complex. The plaintiffs sought to address the malfunctioning gas timers and the board's decision to switch to a ratio utility billing system, which they argued conflicted with the complex’s governing documents and the Rhode Island Condominium Act.The Superior Court consolidated the plaintiffs' motion for a preliminary injunction with a trial on the merits. After a three-day nonjury trial, the Superior Court found in favor of the defendants. The trial justice determined that the notice of the special meeting sent by the board was insufficient but concluded that the plaintiffs' proposed meeting notice was improper because it did not set forth valid transactable business within the association’s authority. The court found for the defendants on count I of the verified complaint and later entered judgment in favor of the defendants on all counts of the plaintiffs' complaint, while dismissing the defendants' counterclaims.The Rhode Island Supreme Court reviewed the case and vacated the part of the Superior Court's judgment finding in favor of the defendants. The Supreme Court held that the plaintiffs had satisfied their obligation to obtain the requisite number of signatures for the special meeting and that their proposed notice complied with the statutory requirements. The court found that the trial justice overstepped by evaluating the merits of the plaintiffs' motions individually and granting relief not sought by the parties. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Song v. Lemoine" on Justia Law

In the late 1980s, Ronald Koziol purchased property in Central Falls, Rhode Island, zoned for heavy industrial use. In 1992, the zoning changed to residential, making the existing automotive repair business a legal nonconforming use. In 2022, Koziol Firearms, Inc. was formed to operate a firearms business on the property. The City’s zoning official denied the request, stating the property was in a residential zone, requiring a use variance. The Zoning Board of Review denied the variance application, and the plaintiff appealed to the Superior Court, also seeking a declaratory judgment that the 1992 zoning amendment was invalid.The Superior Court denied the plaintiff’s motion to present additional evidence and dismissed the zoning appeal, finding the property had a viable use as an automotive repair business. The court dismissed the declaratory judgment count without prejudice, stating it lacked sufficient evidence to rule on the validity of the 1992 zoning amendment.The Rhode Island Supreme Court reviewed the case. The plaintiff argued the trial justice overlooked material evidence and that the zoning classification was in dispute. The City contended the case was moot, the plaintiff lacked standing, and the claim was barred by laches. The Supreme Court found the trial justice did not conduct necessary fact-finding for the declaratory judgment and remanded the case to the Superior Court for a new hearing to determine if the plaintiff should be granted declaratory relief. View "Koziol Firearms, Inc. v. Marchand" on Justia Law

Edgar Sepulveda, as Trustee of the 7 Half Mile Road Living Trust, claimed ownership of a disputed area of land through adverse possession. The land in question bordered his property at 7 Half Mile Road and the property of John Buffum and Angie Salem at 5 Half Mile Road. Sepulveda argued that he had maintained the disputed area exclusively for over ten years. Buffum and Salem, who purchased their property in 2018, disputed this claim and sought a declaratory judgment and damages for trespass.The Superior Court held a bench trial and found in favor of Buffum and Salem. The trial justice determined that Sepulveda's use of the disputed area began only when he installed a new driveway in 2016 or 2017, which did not meet the ten-year requirement for adverse possession. The court also found Sepulveda's testimony lacking in credibility and ruled that Buffum and Salem had proven their claims of trespass and were entitled to declaratory relief.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's judgments. The Supreme Court agreed with the trial justice's credibility assessments and found no clear error in the determination that Sepulveda failed to prove the elements of adverse possession. The court upheld the injunctions requiring Sepulveda to remove the encroaching driveway and prohibiting him from entering the disputed area. View "Sepulveda v. Buffum" on Justia Law

Matthew Moriarty, the defendant, appealed a Superior Court order dismissing his amended counterclaim against Evoqua Water Technologies LLC and Neptune-Benson, LLC. Moriarty's counterclaim sought declaratory relief and tort damages, alleging violations of a non-compete agreement he signed in 2010 while employed by Neptune-Benson, Inc. (NBI). Evoqua acquired Neptune-Benson in 2016 and hired Moriarty in 2017. The plaintiffs sued Moriarty in 2018 for breaching the 2010 agreement, among other claims, and obtained a preliminary injunction in 2019 to enforce the agreement.The Superior Court dismissed Moriarty's counterclaim, citing the litigation privilege for statements made during judicial proceedings. Moriarty's counterclaim included claims for emotional distress, declaratory judgments, constructive discharge, misrepresentation, and interference with business relations, based on alleged false testimony by an Evoqua executive during the preliminary injunction hearing.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's dismissal. The Court held that the litigation privilege protected the executive's testimony, barring Moriarty's claims for emotional distress, misrepresentation, and interference with business relations. The Court also found Moriarty's declaratory judgment claim moot, as the non-compete agreement had expired in 2020, and his constructive discharge claim failed to state a valid cause of action. The Court concluded that Moriarty did not demonstrate that his working conditions were so intolerable that a reasonable person would feel compelled to resign. Thus, the dismissal of Moriarty's amended counterclaim was upheld. View "Evoqua Water Technologies LLC v. Moriarty" on Justia Law