Justia Rhode Island Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the superior court in favor of South County Hospital, Home & Hospice Care of Rhode Island and Emmy Mahoney, M.D. (collectively, Defendants), and dismissing all claims alleged by Plaintiff individually and on behalf of the Guardianship of Joyce C. Willner, holding that the trial justice did not err in dismissing the claims.Plaintiff filed an eight-count complaint against Defendants, individually and as guardian of Joyce Willner, his mother. The trial judge granted Defendants' motions to dismiss and motions for summary judgment, dismissing all claims. The Supreme Court affirmed, holding that the trial justice did not err in (1) dismissing the claims alleged by Plaintiff on behalf of the guardianship because Joyce had no right to be represented by Plaintiff, who was not authorized to practice law; and (2) denying Plaintiff's request to appoint a guardian ad litem. View "Willner v. South County Hospital" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of domestic assault with a dangerous weapon, holding that the trial justice did not abuse her discretion in her evidentiary rulings.On appeal, Defendant argued that the trial justice erred by granting two of the State's motions in limine precluding the jury from hearing evidence of the victim's arrest for gun charges and viewing videos of the victim having engaged in acts of violence. The Supreme Court affirmed, holding that the trial justice did not abuse her discretion when she (1) prevented any mention that Defendant had been arrested on the gun charges, and (2) excluded the videos. View "State v. Medina" on Justia Law

The Supreme Court affirmed in part and quashed in part the final decree of the Workers' Compensation Court (WCC) upholding an award of accidental disability benefits for occupational cancer to Petitioner, holding that the WCC had jurisdiction to hear Petitioner's appeal but erred in finding that R.I. Gen. Laws 45-19.1-1 contains a conclusive presumption that all cancer in firefighters is occupational cancer.Petitioner served as a firefighter for the City of Cranston until he was diagnosed with colon cancer. Petitioner applied for accidental disability benefit based upon his cancer diagnosis. The Retirement Board of the Municipal Employees' Retirement System of Rhode Island denied the application, finding that Petitioner did not prove that his cancer arose out of and in the course of his employment as a firefighter. The WCC then filed his petition arguing that, pursuant to chapter 19.1 of title 45, all cancers contracted by firefighters are presumed to be work-related. The trial judge agreed and reversed the board. The Supreme Court quashed the decree in part, holding that chapter 19.1 of title 45 does not contain any presumption that all cancers in firefighters are occupational cancers. View "Lang v. Municipal Employees' Retirement System of Rhode Island" on Justia Law

The Supreme Court affirmed the order of the family court denying Father's motions to modify visitation placement, ordering Father's visitation to remain suspended, granting in part Mother's motion for a mental health examination of Father, and ordering the parties to engage a counselor for the purposes of Father's psychological evaluation as well as for a parent-child evaluation of Father and the minor children, holding that the family court did not err.The parties in this case were divorced and shared joint custody of their three minor children with physical possession granted to Mother and visitation to Father. After a few years, the family court suspended Father's visitation and ordered him to undergo a mental health examination. The Supreme Court affirmed, holding that the trial justice did not abuse his discretion when he issued the order. View "Tsonos v. Tsonos" on Justia Law

The Supreme Court affirmed the judgments of the superior court granting summary judgment in favor of Plaintiff, Midland Funding, LLC, in these consolidated credit card debt collection appeals, holding that Defendant failed to set forth facts that established a genuine issue of material fact as to whether the credit card accounts were in fact her accounts.The complaints in this case sought to recover the unpaid balance due on two credit card accounts. The district court granted summary judgment for Plaintiff in both cases. On appeal, Defendant argued that there existed an issue of fact as to the ownership of the accounts. The Supreme Court affirmed, holding that the evidence was insufficient to give rise to a genuine issue of material fact. View "Midland Funding LLC v. Raposo" on Justia Law

The Supreme Court affirmed the judgment of the superior court dismissing Plaintiff's complaint against Child and Family Services of Newport County (CFS) alleging defamation, constructive termination, discrimination, and breach of the covenant of good faith and fair dealing, holding that the hearing justice properly dismissed Plaintiff's claims.Specifically, the Court held (1) where the complaint did not allege that CFS made any false statements about Defendant, Plaintiff did not sufficiently allege a claim for defamation; (2) Plaintiff did not properly plead a claim for breach of the covenant of good faith and fair dealing; (3) the complaint did not include sufficient facts to allege a prima facie case of either employment discrimination or a civil rights violation; and (4) the hearing justice did not err in dismissing the amended complaint with prejudice. View "Ferreira v. Child and Family Services of Rhode Island" on Justia Law

The Supreme Court affirmed the judgment of the superior court affirming rulings of the probate court and holding that the father (the decedent)Plaintiffs and Defendant had validly executed a last will and testament on June 9, 2011, holding that the last will and testament executed by the decedent on June 9, 2011 was valid.Plaintiffs alleged that the last will and testament was invalid because, on June 9, 2011, the decedent continued to be subject to a temporary limited guardianship, which included a provision prohibiting the Decedent from revoking or drafting any last will and testament. The superior court justice concluded that because the probate court had, on December 13, 2010, dissolved all portions of the guardianship restricting the decedent's ability to make a will, the last will and testament at issue was not invalid. The Supreme Court affirmed, holding that because the condition limiting the decedent's ability to revoke or draft a last will and testament was extinguished by the probate court in 2010, the last will and testament executed by the decedent in 2011 was valid. View "Duffy v. Scire" on Justia Law