Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court quashed the judgment of the superior court upholding the decision of the Administrative Adjudication Division (AAD) of the Rhode Island Department of Environmental Management (DEM) denying Plaintiffs' request for reasonable litigation expenses in this case alleging violations of the Rhode Island Water Pollution Act (Act) and other regulations, holding that Plaintiffs were entitled to reasonable litigation expenses.Plaintiffs appealed from a notice of violation issued by the DEM alleging ten violations of the Act, the Rhode Island Oil Pollution Control Act, and DEM's regulations. After a hearing before the AAD, Plaintiffs prevailed on all but two of the alleged violations. Plaintiffs requested reasonable litigation expenses under the Equal Access to Justice for Small Businesses and Individuals Act (EAJA), but the AAD hearing officer denied the request. The superior court affirmed. The Supreme Court quashed the superior court's decision, holding that DEM Acted without substantial justification in pursuing charges against Plaintiffs and that this was the type of unjust action by the State that the EAJA was designed to ameliorate. The Court remanded the case with directions to enter a judgment in favor of Plaintiffs in the amount of $69,581.25 for attorneys' fees. View "Rollingwood Acres, Inc. v. Rhode Island Department of Environmental Management" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Petitioner's appeal from a decision of a drug court magistrate upholding a determination by the Sex Offender Board of Review classifying Petitioner as a Level II, moderate-risk sex offender, holding that Petitioner's classification was lawful and proper.On appeal, Petitioner argued that the Board violated his rights to due process, to the presumption of innocence, and to be protected from double jeopardy by relying on alleged impermissible hearsay allegations for conduct for which he was eventually acquitted. The Supreme Court affirmed, holding (1) Petitioner failed to demonstrate that his right to procedural due process was violated; (2) the Board considered numerous factors in making its determination; and (3) Petitioner's classification did not violate the Double Jeopardy Clause, and the Board's actions were not in the context of a criminal trial and did not implicate Petitioner's right to a fair trial. View "DiCarlo v. State" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendants on Plaintiff's complaint alleging various claims under, inter alia, the Rhode Island Wiretap Act, state privacy laws, and federal laws after Defendants installed software on Plaintiff's work computer without his knowledge that intercepted Plaintiff's emails and online activities, holding that summary judgment was properly granted.Plaintiff was employed by Defendants before his arrest and eventual conviction for possession of child pornography. Defendant had installed tracking software on Plaintiff's work computer that recorded Plaintiff's online activities and emailed the record to Defendants. The hearing justice found that the intercepted information was disclosed to the police department, leading to Plaintiff's arrest and conviction, that the claims set forth in Plaintiff's complaint were barred by limitations, and that there was no evidence indicating that Defendants had fraudulently concealed the conduct that formed the basis of Plaintiff's computer crime claims. The Supreme Court affirmed, holding (1) Plaintiff's claims were time-barred; (2) Plaintiff could not benefit from the tolling provisions of R.I. Gen. Laws 9-1-20; and (3) the continuing violation doctrine did not apply to Plaintiff's Rhode Island Wiretap Act claim against Defendants. View "Boudreau v. Automatic Temperature Controls, Inc." on Justia Law

The Supreme Court affirmed the judgment of the superior court reversing the Rhode Island Airport Corporation's (RIAC) 2015 order prohibiting Plaintiff from entering the North Central State Airport, holding that RIAC was not cloaked with the inherent authority to preclude an individual from entering an airport within its jurisdiction without having first issued a formal order.Before the Supreme Court, RIAC argued that it had the authority to ban an individual from any of its airports without issuing a formal order if that individual poses a threat to airport safety or operations and, in there alternative, the no-trespass letter issued by RIAC's attorneys in 2014 and the order issued by RIAC's direction in 2015 could be considered a valid final order the complied with all statutory requirements. The Supreme Court held (1) an order issued by RIAC's director pursuant to R.I. Gen. Laws 1-4-15 is the exclusive means of permanently barring an individual from entering onto an airport on RIAC's jurisdiction; and (2) neither communication sent in this case constituted a valid formal order. View "Blais v. Rhode Island Airport Corp." on Justia Law

In this dispute over the cost of annual premiums for post-retirement life insurance benefits the Supreme Court affirmed the judgment of the superior court entering summary judgment in favor of Plaintiffs - the Rhode Island American Federal of Teachers/Retired Local 8307 and several retirees of the Johnston School Department - holding that the trial justice correctly interpreted R.I. Gen. Laws 16-16-42.Before the Supreme Court, both Plaintiffs and Defendants - the Town of Johnston, the Johnston School Department, the Johnston School Committee, and various municipal officials - argued that section 16-16-42, entitled "Life insurance benefits," is clear and unambiguous, but each party posited a different interpretation. The Supreme Court affirmed the decision of the superior court justice, holding that a proper interpretation of the statute provides that any teacher who, at the time of retirement from service or last day of active employment, has in effect life insurance provided for as a benefit of his or her employment shall, after retirement, be entitled to keep the life insurance policy in effect by paying to the municipality an amount equal to the annual cost of the policy for the individual at the time of the individual's retirement or last day of active employment. View "Rhode Island American Federation of Teachers/Retired Local 8037 v. Johnston School Committee" on Justia Law

The Supreme Court affirmed the decree of the family court that terminated Mother's parental rights with respect to her daughter, holding that the family court justice's findings were not clearly wrong, and the justice did not overlook or misconceive material evidence.On appeal, Mother argued that the family court justice erred in finding unfitness, in concluding that the Department of Children, Youth, and Families made reasonable efforts to provide services to address the circumstances that led to the child's placement in the first instance, and in determining that the termination of Mother's parental rights was in the best interest of the child. The Supreme Court affirmed, holding that legally competent evidence existed to supporting the family court justice's findings. View "In re Violet G." on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of assault with a dangerous weapon and malicious injury to property, holding that the trial justice did not err in denying Defendant's motion for a new trial.In his motion for a new trial, Defendant argued that the jury's verdict was against the weight of the evidence. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice articulated adequate grounds for denying the motion, carefully reviewed the testimony and weighed the evidence before him, and properly concluded, based on his own credibility determinations, that the weight of the evidence supported guilty verdicts as to both counts. View "State v. Najera" on Justia Law

The Supreme Court affirmed the order of the superior court granting summary judgment in favor of Plaintiff as to Plaintiff's claim seeking injunctive relief for Defendants' alleged trespass and permanently enjoining Defendant and its officers, customers, and employees from parking in parking spaces owned by Plaintiff, holding that the hearing justice did not err in granting summary judgment on this claim.This case centered around a dispute over parking spaces in the Watch Hill section of Westerly. In an earlier case, Defendants sued Plaintiff regarding the parking spaces. Plaintiff later brought this action. After a hearing justice granted summary judgment on its injunctive relief claim, Defendants appealed, arguing that the trial justice erred by failing to order that the dispute be arbitrated and granting Plaintiff injunctive relief based on res judicata and collateral estoppel. The Supreme Court affirmed, holding (1) Defendants waived their right to arbitration of the injunctive relief claim; and (2) there existed identity of issues between the first action and the current dispute. View "JHRW, LLC v. Seaport Studios, Inc." on Justia Law

The Supreme Court affirmed the judgment of the superior court affirming a decision of the Rhode Island Department of Labor and Training (DLT) that denied Petitioners' wage and hour claims against Delta Airline, Inc., holding that the superior court did not err in affirming the DLT's finding that R.I. Gen. Laws 25-3-3 was preempted by federal law.Petitioners were customer service agents for Delta at its facility at the T.F. Green Airport in Warwick, Rhode Island. Petitioners filed separate individual "nonpayment of wages" complaints with DLT, alleging that Delta violated the provisions of section 25-3-3 by failing to pay Petitioners time-and-a-half for hours worked on Sundays and holidays. The hearing officer determined that section 25-3-3 was preempted by section 49 U.S.C. 41713(b)(1) of the Airline Deregulation Act (ADA). The superior court affirmed. The Supreme Court affirmed, holding that Petitioners' claims were preempted by the ADA. View "Brindle v. Rhode Island Department of Labor & Training" on Justia Law

The Supreme Court affirmed the postjudgment order of the family court in favor of Judith Cusick requiring Maurice Cusick to submit to limited genetic testing for the benefit of the parties' minor children, holding that the hearing justice made sufficient findings of fact and did not overlook or misconceive any evidence.Judith, Maurice's former wife, filed her motion for genetic testing after Maurice was diagnosed with a genetic heart condition that poses significant risks that can result in sudden death. The hearing justice granted the motion. Maurice appealed, arguing for the first time that ordering him to submit to genetic testing violated his constitutional rights to privacy and due process. The Supreme Court affirmed, holding (1) Maurice's constitutional challenges were not property before the Court; and (2) the hearing justice's conclusion that genetic testing was in the best interest of the children was supported by the evidence, and the order was both balanced and reasonable. View "Cusick v. Cusick" on Justia Law