Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the superior court convicting Defendant of two counts of first-degree child molestation sexual assault and two counts of second-degree child molestation sexual assault, holding that the trial justice did not err by admitting evidence of an uncharged incident and by denying Defendant's motion for a new trial.Specifically, the Supreme Court held (1) Defendant's argument that evidence of a previous encounter Defendant had with the police, which resulted in neither charges against Defendant nor injuries to the victim, was improperly admitted under R.I. Evid. R. 404(b) was waived; and (2) the trial justice did not overlook or misconceive any material evidence and did not clearly err by denying Defendant's motion for a new trial. View "State v. Mensah" on Justia Law

The Supreme Court vacated the judgment of the superior court granting summary judgment in favor of Plaintiffs and declaring that Plaintiffs were entitled to unobstructed access to a beach easement and may cross Defendants' properties to reach that easement, holding that genuine issues of material fact remained, precluding summary judgment.At trial, Plaintiffs asserted that their property enjoyed an unrestricted easement appurtenant to the beach by virtue of the original easement to cross over the beach and that they were entitled access to the beach because they held a right-of-way over all three of defendants' properties based on the doctrines of easement by implication and easement by necessity. The hearing justice granted summary judgment in favor of Plaintiffs. The Supreme Court vacated the judgment, holding that where the hearing justice did not first determine whether an implied easement or easement by necessity existed for Plaintiffs to cross over Defendants' properties, the case must be remanded for further fact-finding. View "McElroy v. Stephens" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of the State and Lieutenant Scott Raynes and the Community College of Rhode Island (CCRI), the Council on Postsecondary Education, and Captain Timothy Poulin, holding that the superior court did not err.Plaintiff brought a complaint alleging that Defendants terminated him in violation of the Rhode Island Whistleblowers' Protection Act and that Lieutenant Raynes and Captain Poulin violated 42 U.S.C. 1983 when they took action against Plaintiff from being continuously employed due to his whistleblowing activity. The hearing justice dismissed Plaintiff's claims. Plaintiff appealed the dismissal of his complaint and the denial of his motion to amend his complaint. The Supreme Judicial Court affirmed, holding (1) the hearing justice correctly concluded that Plaintiff failed to state a valid claim under the Act because Plaintiff's actions did not qualify as protected activity; and (2) the hearing justice did not err in denying Plaintiff's motion to amend his complaint on the ground that his claim under 42 U.S.C. 1983 was barred by the statute of limitations. View "Crenshaw v. State" on Justia Law

The Supreme Court affirmed the judgment of the superior court for possession of certain property in favor of Plaintiff pursuant to the granting of summary judgment for Plaintiff, holding that when Plaintiff purchased the property at a foreclosure sale, all interests inferior to the foreclosed mortgage were extinguished and that no genuine issue of material fact remained.In 2008, MCH Realty, LLC, the then-owner of the property, entered into a lease agreement with Unetixs Vascular, Inc. to lease the property. In 2013, MCH executed a mortgage deed to DBS Bank Ltd. secured by its interest in the property. DBS later assigned its interest in the mortgage to CFS. In 2016, MCH and Unitexs extended the term of the lease. In 2017, CFS foreclosed on the mortgage and purchased the property at a foreclosure sale. CFS then filed a complaint seeking to evict Unetisx and another tenant (together, Tenants) and MCH from the property. A hearing justice granted the motion, ruling that the mortgage was superior to the Tenants' unrecorded leases and that, therefore, the leases were extinguished upon foreclosure. The Supreme Court affirmed, holding that CFS was entitled to judgment as a matter of law. View "CFS 915, LLC v. Unetixs Vascular, Inc." on Justia Law

The Supreme Court vacated the judgment of the superior court denying the motion for summary judgment filed by the Town of Exeter and the Town of Richmond (together, the Towns) and granting summary judgment for the State, holding that the trial court erred in finding that the Comprehensive Planning and Land Use Regulation Act, R.I. Gen. Laws chapter 22.2 of title 45, provides the exclusive procedure to resolve zoning disputes between the State and municipalities.A hearing justice concluded that the State was not required to obtain municipal approval and permits before beginning a project. The Supreme Court held (1) while section 45-22.2-10(g) governs comprehensive planning disputes between the State and a municipality it does not confer immunity on the State from application of a municipality's zoning ordinance; (2) the Act does not supersede the balancing-of-interests test set forth in Blackstone Park Improvement Ass'n v. State Board of Standards & Appeals, 448 A.2d 1233 (R.I. 1982); and (3) the State must apply to a municipal zoning board prior to bringing an action in superior court for a trial justice to balance the interests of the State against the interests of the municipality with respect to a proposed project. View "Town of Exeter v. State" on Justia Law

In this property dispute, the Supreme Court affirmed the judgment of the superior court in favor of Defendant, holding that the trial justice did not misconceive or misconstrue the evidence at trial or err as a matter of law in concluding that Plaintiffs had not satisfied the elements for claiming the disputed property by adverse possession.In 2009, when Plaintiffs purchased their property in Buttonwoods, the believed they had also purchased the waterfront lot across the street from their home. Two years later, Plaintiffs commissioned a property survey showing that part of the land described in their deed was also included in an eighty-foot-wide public way owned by the Buttonwoods Beach Association (BBA). Plaintiffs brought this lawsuit alleging that they owned the property by adverse possession and acquiescence. The superior court entered judgment for the BBA. The Supreme Court affirmed, holding that the trial justice did not err in concluding that Plaintiffs had not demonstrated ownership of the entire waterfront lot by adverse possession. View "Clark v. Buttonwoods Beach Ass'n" on Justia Law

In this property dispute, the Supreme Court affirmed in part and vacated in part the judgment of the superior court granting Defendants' motion for summary judgment based on the ground of prosecutorial immunity, holding that the hearing justice erred in applying prosecutorial immunity to the Building and Zoning Official for the Town of Cumberland (Building Official Hall) and the Town of Cumberland (Town).Plaintiffs sued the Solicitor for the Town of Cumberland (Solicitor Hefner), Building Official Hall, and the Town, claiming negligence, private nuisance, trespass, intentional infliction of emotional distress and seeking declaratory judgment and injunctive relief after Plaintiffs' neighbor prevailed on an action against the Town regarding its agreement with the Town regarding a retaining wall abutting Plaintiffs' property. The hearing justice granted summary judgment in favor of Defendants. The Supreme Court vacated the decision in part, holding (1) Solicitor Hefner was entitled to prosecutorial immunity; (2) Building Official Hall failed to meet his burden of proof as to prosecutorial immunity; and (3) because this Court is vacating the superior court's decision with respect to Building Official Hall, the summary judgment decision with respect to the Town is also vacated. View "Diorio v. Hines Road, LLC" on Justia Law

The Supreme Court affirmed the order of the superior court dismissing Plaintiff's claims against Defendants seeking a declaratory judgment concerning the propriety of the foreclosure of Plaintiff's property, holding that the superior court did not err.Plaintiff named as defendants Residential Credit Solutions, Inc.; FV REO I, LLC; Franklin Venture, LLC; and DLJ Mortgage Capital, Inc. As part of her complaint, Plaintiff sought to quiet title concerning the property at issue and an award of punitive damages, attorneys' fees, and costs. The hearing justice dismissed Plaintiff's complaint for failure to serve all indispensable parties. The Supreme Court affirmed, holding that Plaintiff's failure to meaningfully discuss the issues raised on appeal was fatal to Plaintiff's appeal. View "Osifodurin v. Residential Credit Solutions, Inc., et al." on Justia Law

The Supreme Court denied and dismissed Defendant's appeal from an order of the family court denying what Father characterized as a motion to receive a child support credit for Social Security Disability Insurance (SSDI) benefits that were paid directly to Mother for the care of the parties' child, holding that this appeal was not properly before the Court.The Supreme Court noted that, even though Father's motion was styled as a motion for credit, it was, in fact, a motion to modify the amount of child support Father was obligated to pay. Because matters relating to the modification of child support are not appealable, the Supreme Court declined to reach the merits of the appeal because it was not properly before the Court. View "Evans v. Evans" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Defendant's motion to vacate an illegal sentence and judgment, holding that the hearing justice did not act arbitrarily or capriciously when he found that Defendant violated the conditions of his probation to which he was sentenced after his 2009 conviction.In 2009, Defendant was sentenced to a term of imprisonment plus a suspended sentence, with probation. In 2018, Defendant pled nolo contendere to other offenses. Because Defendant was on probation at the time of the 2018, the hearing justice found Defendant to have violated the conditions of his 2009 probation and sentenced him on the same sentence previously imposed. Defendant filed a motion to vacate an illegal sentence, which the hearing justice denied. Before the Supreme Court, Defendant asserted that there were no conditions of probation prior to the enactment of R.I. Gen. Laws 12-19-8.1 in 2017. Therefore, Defendant argued that because he was sentenced to probation before 2017, he could not have violated any probation condition. The Supreme Court affirmed, holding that section 12-19-8.1 codified what had long been recognized as conditions of probation in Rhode Island. View "State v. Chandler" on Justia Law