Justia Rhode Island Supreme Court Opinion Summaries

The case involves the Newport School Committee and the Cumberland School Committee (collectively, plaintiffs) and the Rhode Island Department of Education and the Rhode Island Council on Elementary and Secondary Education (collectively, defendants). The dispute arose when the plaintiffs refused to reimburse the Department of Children, Youth, and Families (DCYF) at the "per-pupil special-education" rate for the cost of educating children who were placed in residential treatment programs by DCYF but were not receiving special-education services. The Family Court had placed two children in the temporary custody of DCYF and designated Newport and Cumberland as the residences of the children's custodial parents for the purpose of determining the municipalities' financial responsibility for the children's education.The Commissioner of Elementary and Secondary Education agreed with DCYF's argument that the municipalities were required to pay the per-pupil special-education rate according to the unambiguous language of the relevant statutes. The Commissioner issued two decisions ordering Newport and Cumberland to reimburse DCYF for the cost of educational services provided to the children at the special-education rate. After the Council on Elementary and Secondary Education denied the municipalities' independent appeals of the Commissioner's decisions, the municipalities appealed to the Superior Court. The trial justice consolidated the two cases and issued a written decision, determining that the clear and unambiguous language of the statute required the designated city or town to pay its share of the cost of educational services to DCYF rather than the higher, per-pupil special-education rate.The Supreme Court of Rhode Island reviewed the case and found that there is nothing in the relevant statutes that expressly obligates a municipality to pay the per-pupil special-education rate when the child in question is not actually receiving special-education services. The court concluded that municipalities are not required to reimburse DCYF at the per-pupil special-education rate when there were no special education services rendered and thus, no special education costs incurred. The court directed the parties to file supplemental briefs to resolve the remaining question of what reimbursement, if any, DCYF should receive for the educational cost of non-special-education students placed in residential treatment programs that include the delivery of educational services. View "Newport School Committee v. Rhode Island Department of Education" on Justia Law

This case involves a medical negligence claim brought by John Armour, individually and as personal representative of the Estate of Judith Armour, against David Bader, M.D., Neil Brandon, M.D., and South County Hospital Healthcare System d.b.a. South County Cardiology. The plaintiff alleges that the defendants negligently failed to provide adequate follow-up and treatment to Judith Armour following a stress test, which ultimately led to her death from a heart attack the next day. The stress test results were "markedly abnormal" and indicated potential significant coronary artery disease, but Mrs. Armour was sent home after the staff determined she was medically stable.The case was tried in the Washington County Superior Court. The jury heard testimony from various witnesses, including the nurses, the defendant-doctors, Mrs. Armour’s family, and expert testimony from both sides regarding the applicable standard of care and causation. The jury returned a verdict in favor of the defendants on all counts. The plaintiff filed a motion for a new trial, arguing that the jury’s verdict was against the fair preponderance of the evidence and that the trial justice erred in several respects. The trial justice denied the motion, concluding that the overwhelming weight of the evidence supported the jury’s verdict.On appeal to the Supreme Court of Rhode Island, the plaintiff argued that the trial justice erred in refusing to issue a jury instruction based on a previous court decision, erred in permitting defendants’ standard-of-care expert to utilize the referring doctor’s records, and erred in limiting cross-examination of that expert regarding a particular study. The Supreme Court found that the trial justice's refusal to issue the requested jury instruction was prejudicial and constituted reversible error. The court also found that it was an error to allow the expert to use the referring physician’s records to support his opinions as defendants did not have access to this information when determining if Mrs. Armour was stable. Lastly, the court concluded it was an abuse of discretion to limit cross-examination on a point that went to the heart of the most important standard-of-care issue in the case. The judgment of the Superior Court was vacated and the case was remanded for a new trial. View "Armour v. Bader" on Justia Law

The case involves Nicholas Finnigan, who was convicted of one count of second-degree child molestation following a jury-waived trial in the Superior Court. The incident allegedly occurred in February 2012, when the victim, R.B., was under fourteen years old. Finnigan was sentenced to ten years, with fifty-four months to serve and the remainder suspended, and ten years of probation. Finnigan appealed the conviction, arguing that the trial justice overlooked or misconceived material evidence.The Superior Court heard testimonies from several witnesses, including the victim, R.B., who testified that Finnigan touched her inappropriately while she was sleeping in her bedroom. Other witnesses corroborated aspects of R.B.'s account, including her mother and aunt who testified that they saw Finnigan leaving R.B.'s room on the night of the incident. Finnigan denied the allegations and claimed he never entered R.B.'s bedroom on the night in question. The trial justice found R.B. to be a credible witness and concluded that Finnigan was guilty of second-degree child molestation.The case was brought before the Supreme Court of Rhode Island. Finnigan argued that the trial justice overlooked or misconceived material testimony about the night of the alleged incident and failed to properly weigh the conflicting testimony regarding the actual date of the alleged incident. The Supreme Court, after reviewing the record, concluded that sufficient competent evidence existed to support the trial justice’s general finding of guilt beyond a reasonable doubt on the charge of second-degree child molestation. The court affirmed the judgment of the Superior Court, stating that the trial justice did not misconceive or overlook the inconsistent testimony about the date of the incident. The court also noted that there is no requirement of independent corroboration for sex-offense cases. View "State v. Finnigan" on Justia Law

The defendant, Lydia Alicea, was charged with violating a law between February 18, 2017, and August 1, 2017. On June 19, 2020, she pleaded nolo contendere and was given a two-year deferred sentence and ordered to pay $1,800 in restitution. Alicea entered into a deferred-sentence agreement with the Office of the Attorney General, agreeing to the terms of her sentence, including the payment of restitution. However, she failed to pay the court-ordered restitution in accordance with the agreement. Almost two years later, the state filed a notice of violation and Alicea appeared before a Superior Court magistrate.The magistrate inquired whether Alicea had the ability to pay the outstanding balance before the expiration of her sentence. Alicea represented that she could satisfy the outstanding amount before the deferred-sentence agreement expired, as she had recently become employed. However, she failed to make any payments towards her outstanding balance. The court scheduled a violation hearing based on Alicea’s failure to comply with the restitution obligation of her deferred-sentence agreement. At the hearing, Alicea submitted a hand-written financial statement in support of her argument that she was unable to pay restitution. The court found Alicea in violation of the deferred-sentence agreement and imposed a sentence of three years of probation and ordered her to pay $36.15 in monthly installments toward the outstanding restitution amount.Alicea appealed the magistrate’s decision to a justice of the Superior Court. The trial justice denied the appeal and the restitution payments were set to resume. Alicea then appealed to the Supreme Court of Rhode Island. The Supreme Court vacated the judgment of the Superior Court and remanded for further proceedings, stating that Alicea was entitled to an evidentiary hearing regarding her ability to pay before a sentence could be imposed. View "State v. Alicea" on Justia Law

This case involves four individuals, Joao Neves, Keith Nunes, Pablo Ortega, and Mario Monteiro, who were convicted of various crimes in Rhode Island and were serving multiple sentences, including life sentences. The issue at hand is the interpretation of a Rhode Island statute, G.L. 1956 § 13-8-13(e), which was enacted in 2021 and provides that any person sentenced for any offense committed prior to their twenty-second birthday, other than a person serving life without parole, shall be eligible for parole review after serving no fewer than twenty years' imprisonment.The state argued that the statute applies only to individuals serving a single sentence and does not require the aggregation of multiple sentences for parole eligibility. The respondents, on the other hand, argued that the statute applies to "any offense," and thus requires the aggregation of multiple sentences, including consecutive sentences, for parole eligibility.The trial justice agreed with the respondents and ordered that each respondent be immediately released on parole. The state appealed, arguing that the trial justice's interpretation of the statute violated the separation-of-powers doctrine by modifying judicial sentences.The Supreme Court of Rhode Island held that the statute mandates the aggregation of a qualified offender’s sentences, including consecutive sentences, for parole eligibility. The court also concluded that the statute, as interpreted, does not violate the separation-of-powers doctrine. However, the court found that the trial justice erred in ordering each respondent to be immediately released on parole, as the statute only provides a qualified offender the opportunity to appear before the parole board, not the right to be paroled. The court affirmed in part and vacated in part the judgments of the lower court, and remanded the cases to the parole board for further proceedings. View "Neves v. State of Rhode Island" on Justia Law

Edward Mather, the defendant, was charged with multiple counts of domestic assault, vandalism, and violation of a no-contact order. Following his arraignment, he was ordered to undergo a psychiatric evaluation to determine his competency to stand trial. The evaluation concluded that Mather was incompetent to stand trial and required hospitalization. Subsequently, he was committed to an outpatient facility, LaBelle House Group Home, under the custody of the Department of Behavioral Healthcare, Developmental Disabilities and Hospitals (BHDDH).The Superior Court held a commitment hearing and based on a report from BHDDH, found Mather remained incompetent to stand trial. The court ordered Mather to remain committed to BHDDH's custody but allowed him to be placed in an outpatient facility without endangering himself or others. The court also ordered that if Mather violated the conditions of the order, engaged in threatening or aggressive behavior, or required hospitalization, he should be immediately returned to Eleanor Slater Hospital.Mather filed a petition to discharge from the detention order of commitment in both of his pending criminal matters. He argued that his continued institutionalization at the outpatient facility restricted his liberty and violated due process. The trial justice denied Mather's petitions, reasoning that his commitment to the outpatient facility did not constitute "detention" pursuant to the relevant statute. Mather sought review of the decision, and the Supreme Court of Rhode Island granted the petitions, consolidated the cases for review, and issued the writ.The Supreme Court of Rhode Island quashed the orders of the Superior Court and remanded the matter for further proceedings. The court held that the trial justice committed a reversible error of law when he denied the petitions to discharge from detention orders of commitment. The court concluded that Mather's continued commitment no longer bore a reasonable relationship to the purpose of his commitment under the relevant statute. The court held that where a defendant is found to be incompetent to stand trial and competency is nonrestorable prior to the statutory dismissal period, the defendant is entitled to be discharged from detention under the order of commitment thirty days thereafter. View "State v. Mather" on Justia Law

The defendant, Dari Garcia, was charged with fifteen counts related to a series of events that occurred on August 17, 2014, at a home in North Providence, Rhode Island. These events resulted in the death of Richard Catalano and injuries to Lorie Catalano and Christopher Tamelleo. The charges included first-degree murder, discharging a firearm while committing a crime of violence, conspiracy, burglary, felony assault, using a firearm during a crime of violence, carrying a firearm without a license, possession of a firearm after conviction of a crime of violence, alteration of marks of identification on a firearm, and committing a crime of violence when possessing a stolen firearm.The case was tried in the Superior Court for Providence County. During the trial, the defendant moved to suppress his verbal statements made to a Rhode Island Deputy Sheriff while he was undergoing treatment at a hospital, arguing that the inquiry constituted custodial interrogation. The trial justice denied the motion. The defendant also filed a motion to dismiss one of the counts on double jeopardy grounds, but the trial justice did not rule on this motion at that time. After a trial, the jury found the defendant guilty on thirteen of the fifteen counts. The defendant subsequently filed a motion for a new trial, which was denied by the trial justice. The defendant was sentenced to multiple terms of imprisonment, including three life sentences.On appeal to the Supreme Court of Rhode Island, the defendant raised several issues, including whether the trial justice erred in allowing the state to strike a prospective juror, whether the trial justice erred in allowing certain testimony, whether the trial justice erred in limiting the cross-examination of a witness, whether the trial justice erred in allowing two brothers to testify in the presence of the jury, whether the trial justice impermissibly aided the prosecution, whether the defendant's convictions violated the double jeopardy clause, whether certain statements made by the prosecutor in her closing argument were unduly prejudicial, and whether the trial justice's sentencing of the defendant resulted in a "de facto life without parole sentence."The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. The court held that the trial justice did not err in her handling of the various issues raised by the defendant. The court also held that the defendant's sentence did not violate the double jeopardy clause and that the prosecutor's statements in her closing argument were not unduly prejudicial. The court further held that the defendant's argument that he received a "de facto life without parole sentence" was not properly preserved for appeal. View "State v. Garcia" on Justia Law

This case involves a dispute between the University of Rhode Island Board of Trustees and the University of Rhode Island (plaintiffs) and the Hellenic Society Paideia – Rhode Island Chapter (defendant). The dispute arose from a breach-of-contract related to the construction of a Center for Hellenic Studies at the University of Rhode Island. The plaintiffs and defendant had entered into a Ground Lease Agreement that established the parameters for this construction project. The defendant failed to construct the Center for Hellenic Studies within the agreed timeframe, leading to litigation.The Superior Court stayed the litigation pending arbitration, as per the mandate. The arbitration proceedings were held, and the arbitrator issued a decision. The arbitrator found that the defendant had breached the lease agreement by failing to construct the Center for Hellenic Studies within the requisite timeframe, among other failures. The arbitrator also determined that a joint venture did not exist between the parties. The arbitrator directed the defendant to reimburse the plaintiffs for the cost and expenses that they will incur in their efforts to restore the construction site to its prior status.The plaintiffs filed a motion in Superior Court to confirm the arbitration award, which the defendant objected to and cross-moved to vacate. The trial justice granted the plaintiffs' motion to confirm the award and denied the defendant's cross-motion to vacate. The trial justice declined to review the arbitrator’s determination that the plaintiffs properly terminated the lease agreement and rejected the defendant’s objection to the arbitral remedy.The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. The court concluded that the arbitrator's award drew its essence from the parties' lease agreement and lacked any indication that the arbitrator manifestly disregarded the law. The court rejected the defendant's arguments that the arbitrator had exceeded his authority. The court affirmed the trial justice's order confirming the arbitration award. View "The University of Rhode Island Board of Trustees v. Hellenic Society Paideia-Rhode Island Chapter" on Justia Law

The defendant, Anton Liverpool, was convicted for violating the terms of his probation following a hearing in the Superior Court of Rhode Island. The violation was based on an incident where Liverpool was accused of disorderly conduct. A woman reported to the Providence police that she encountered Liverpool exposing himself and engaging in masturbation while she was walking to work. She also reported that he followed her and continued to expose himself. The police apprehended Liverpool less than an hour later and conducted a show-up identification procedure, where the woman identified Liverpool as the man from her encounter.The Superior Court conducted a two-day violation hearing based on Liverpool's two prior convictions. The state presented evidence from the woman and a police officer. The woman testified about her interaction with Liverpool, described his appearance, and made an in-court identification of him. She also reviewed two surveillance videos of her interaction with Liverpool. The police officer testified about his response to the woman's 911 call, his review of the footage, and his apprehension of Liverpool. Liverpool did not present any evidence. The trial justice found that the state had demonstrated that Liverpool failed to keep the peace and maintain good behavior, thereby violating the terms of his probation.Liverpool appealed the decision, arguing that the trial justice erred in admitting video footage that lacked the required foundation and violated the Confrontation Clause of the Sixth Amendment. He also argued that the trial justice erred in relying on a suggestive show-up identification conducted by the Providence police. The Supreme Court of Rhode Island affirmed the judgment of the Superior Court, concluding that the trial justice did not err in his determination. The court found that there was ample credible evidence upon which the trial justice based his finding, and that the trial justice properly considered the record evidence in determining that Liverpool violated the terms of his probation. View "State v. Liverpool" on Justia Law

The case revolves around a plaintiff, Carol Allen, who slipped and fell on the steps of Newport City Hall while exiting the building after paying her property taxes. At the time of the incident, there was light to moderate snowfall, and the steps were covered with a slushy film. Allen suffered a severe head injury as a result of the fall, which led to multiple seizures and the loss of her ability to taste and smell. She filed a negligence lawsuit against the city and its employees, alleging they failed to properly treat the stairs for adverse weather conditions.The Superior Court ruled in favor of Allen, finding that the city and its employees had a duty to clear the steps of snow and ice, even during an ongoing storm, due to the unusual circumstances of the case. The court found that the city's failure to apply ice melt and take other protective measures exacerbated the risks inherent in using the stairs during a storm. The court also found that Allen was 35 percent comparatively negligent for her fall.The city and its employees appealed the decision to the Supreme Court of Rhode Island. The Supreme Court vacated the judgments of the Superior Court, ruling that the city and its employees did not have a duty to clear the steps until a reasonable time after the storm had ended. The court found that the city's failure to take precautionary measures did not exacerbate the risks already inherent in traveling during a storm. Therefore, the court concluded that there were no unusual circumstances that triggered the city's duty prior to the end of the storm. The case was remanded for entry of judgment in favor of the city and its employees. View "Allen v. Sitrin" on Justia Law