Justia Rhode Island Supreme Court Opinion Summaries

In this slip-and-fall case, the Supreme Court affirmed the judgment of the superior court in favor of Defendants, holding that the trial justice properly granted summary judgment in favor of Defendants.Plaintiff sustained injuries when she tripped over a speed bump in the parking lot of a Walgreens Pharmacy. Plaintiff sued Walgreens and the landlords of the property, alleging negligence, premises liability, and vicarious liability. The trial justice granted judgment judgment for Defendants. The Supreme Court affirmed, holding that Plaintiff failed to produce competent evidence to establish that the speed bump presented an unreasonable danger or that it was negligently constructed and maintained. View "Yanku v. Walgreen Co." on Justia Law

The Supreme Court affirmed the judgment of the superior court granting Plaintiffs' request for declaratory and injunctive relief and ruling that the Town of Barrington lacked authority under its Home Rule Charter to enact an ordinance banning the sale of flavored tobacco products and prohibiting the providing of any tobacco products to persons under the age of twenty-one (the Tobacco Ordinance), holding that the Town lacked the authority to enact the Tobacco Ordinance.Specifically, the Court held that, while the Tobacco Ordinance was enacted to protect public health and safety, the ordinance constituted legislation concerning a matter of statewide concern, and therefore, it fringed upon the power of the state. Further, because the Town lacked the authority under its Home Rule Charter to enact the ordinance, the hearing justice did not err in declining to decide whether the ordinance was preempted by state law. View "K&W Automotive, LLC v. Town of Barrington" on Justia Law

The Supreme Court quashed the order of the district court denying Appellant's motion to seal his records under R.I. Gen. Laws 12-1-12 on the grounds that because Defendant was charged with a civil violation rather than a criminal violation, he was not entitled to relief under the statute, holding that a person charged with a first violation of driving with a suspended license is entitled to have his records sealed under the provisions of section 12-1-12.In denying Defendant's motion to seal his records, the trial judge looked to the language of the statute, noting that it speaks only to criminal cases and is silent with respect to civil violations, and concluded that the Legislature had provided no mechanism to seal or expunge civil violations. The Supreme Court disagreed, holding that where Defendant was detained by police but not arrested or charged with an offense, he was entitled to the benefits of section 12-1-12(a) with respect to the destruction and sealing of his records. View "State ex rel. Coventry Police Department v. Charlwood" on Justia Law

The Supreme Court affirmed the judgment of the family court terminating Plaintiff's marriage to Defendant on the grounds of irreconcilable differences, holding that the trial justice neither erred nor abused her discretion in her assignment of specific martial assets or in determining the amount of Plaintiff's child support obligation.On appeal, Plaintiff challenged several of the specific asset allocations as well as the amount of child support Plaintiff was ordered to pay Defendant, arguing that there was either error or abuse of discretion in the part of the trial justice. The Supreme Court disagreed and affirmed, holding that the trial court did not err in its allocation and distribution of Defendant's investment accounts, in offsetting spending from marital assets, in allocating assets from individual bank accounts, and in ordering Plaintiff to pay a certain amount of child support. View "Boschetto v. Boschetto" on Justia Law

The Supreme Court affirmed the judgment of the superior court entering summary judgment in favor of the Town of Johnston and dismissing Plaintiff's suit alleging claims of governmental promissory estoppel and deprivation of property rights after the Town denied Plaintiff's requests for health benefits set forth in Ordinance 767, holding that Plaintiff was not eligible to receive benefits under the ordinance.Plaintiff served on the Johnston Town Council from 1981 until 1994. In 1989, the Town passed and adopted Ordinance 767, which established various benefits for certain town officials. In 1993, Ordinance 767 was repealed by Ordinance 913. In the early 2000s Plaintiff made several demands on the Town for the health benefits set forth in Ordinance 767, arguing that his entitlement to those benefits had vested as of 1991. After the Town denied those requests Plaintiff filed suit. The superior court granted summary judgment for the Town. The Supreme Court affirmed, holding (1) the clear and unambiguous language of Ordinance 767 indicates that Plaintiff was not eligible to receive benefits under the ordinance; and (2) Ordinance 767 sought to create a right to health benefits that did not previously exist, and therefore, the enactment could not be deemed a remedial ordinance. View "Zanni v. Town of Johnston" on Justia Law

The Supreme Court affirmed an order and judgment of the superior court granting the Rhode Island Department of Health's (Department) motion to dismiss Physicians' complaint, quashed a later judgment of the superior court granting the physicians' motion to enter default judgment against the Department, and remanded this case for further proceedings, holding that a default judgment against an agency in this case was inappropriate.The Department made a finding of unprofessional conduct against Physicians. Physicians move to dismiss the charges filed against them. The hearing officer denied the motion. Physicians then filed a complaint appealing the order. A hearing justice granted the Department's motion to dismiss the complaint without prejudice to them seeking review after they had exhausted their administrative remedies. The Supreme Court then granted Physicians' petition for writ of certiorari, and a second hearing justice granted Physicians' motion to enter default judgment because the Department did not submit the certified administrative record of the appeal. The Supreme Court held (1) the first hearing justice correctly found that the case was interlocutory and therefore premature; and (2) the second hearing justice exceeded his discretion when he entered default judgment in favor of Physicians. View "Banki v. Fine" on Justia Law

The Supreme Court affirmed the decree of the superior court foreclosing Crown Realty LLC's right of redemption to real property that was the subject of a 2017 tax sale, holding that that the superior court justice properly entered a decree forever barring Crown Realty's right of redemption.Crown Realty was the owner of real property that was sold to Plaintiff at a tax sale conducted by the Town of North Providence. Plaintiff failed a petition to foreclose the right of redemption, citing a failure to any interested party to redeem the property. The justice determined that Crown Realty's right of redemption was barred. One week later, a final decree was entered foreclosing the right of Crown Realty to redeem the property. The Supreme Court affirmed, holding (1) Crown Realty's request that an exception to Conley v. Fontaine, 138 A.3d 756 (R.I. 2016), be applied in this case was misplaced; and (2) no implied-in-fact contract existed between the parties. View "Conley v. Crown Realty, LLC" on Justia Law

The Supreme Court vacated Defendant's judgment of conviction on one count of first-degree child molestation sexual assault and remanded the case to the superior court for a new trial, holding that the trial justice erred in denying Defendant's motion to pass the case after the prosecutor's statements during closing argument about Defendant's courtroom demeanor and behavior toward the complainant.Specifically, the Court held (1) the prosecutor's statements regarding Defendant's courtroom demeanor had the potential for unfair prejudice, and a curative instruction could not overcome the prejudice in this case; (2) the trial justice erred in admitting some, but not all, of the evidence pertaining to a police investigation into Defendant for possession of child pornography; and (3) Defendant's claim that the trial justice erred in failing to safeguard Defendant's right to a fair trial based on various claims related to the presence of members of a motorcycle group known as Bikers Against Child Abuse in the courtroom during trial was not properly before the court. View "State v. Bozzo" on Justia Law

In this consolidated appeal from an order of the superior court concluding that former Central Falls Mayor and former members of the Central Falls City Council (collectively, the elected officials) were not entitled to indemnification from the State for attorneys' fees and costs incurred over the course of this action the Supreme Court held that the superior court correctly concluded that the State was not required to indemnify the elected officials.These cases arose out of conflicts between a receiver, appointed for the City of Central Falls pursuant to the Financial Stability Act, and the elected officials. After the Supreme Court resolved the issue of the constitutionality of the Financial Stability Act the parties continued to litigate about the issue of attorneys' fees and indemnification. The Supreme Court concluded that the elected officials were entitled to indemnification. At issue in this appeal was who was required to indemnify the elected officials for their legal fees and costs. The superior court held that the City was required to indemnify the elected officials. The Supreme Court affirmed, holding that the elected officials were entitled to indemnification from the City but not from the State. View "Shine v. Moreau" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree murder and first-degree arson, holding that the trial justice was not clearly wrong in denying Defendant's motion for a new trial.On appeal, Defendant argued that the trial justice was clearly wrong when she denied his motion for a new trial because the weight of the evidence did not support the jury's verdict. The Supreme Court affirmed, holding that the evidence supported a finding that Defendant was the perpetrator and that the verdict was not against the weight of the evidence because the evidence supported a finding of premeditation. View "State v. Gumkowski" on Justia Law