Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendants and dismissing Plaintiff's action claiming violation of restrictive covenants and breach of the duty of quiet enjoyment arising out of Defendants' alleged wrongful construction of a multi-story structure on their property, holding that summary judgment was properly granted.Defendants failed to get approval prior to building, as required under the plain language of the restrictive covenant at issue. However, Defendants ultimately received the required approval. The requirements were not building requirements but, rather, the requirement to submit plans for approval prior to building. The Supreme Court held that because the requested relief for Defendants' breach of the restrictive covenants would lead to a futile result, the hearing justice did not err in granting Defendants' motion for summary judgment. View "Pollak v. 217 Indian Avenue, LLC" on Justia Law

The Supreme Court affirmed in part and vacated in part the order of the family court denying Father's motion for a new trial following an order that denied Father's motion to change custody and awarded sole custody of the parties' children to Mother, holding that the trial justice improperly determined that Plaintiff should be awarded sole custody.Following the entry of final judgment of divorce Father moved to modify placement, seeking an order awarding him placement of the children. The trial justice granted Mother's motion to dismiss, finding that Defendant had not met his burden of showing a substantial change in circumstances. The trial justice then found that the parents could not co-parent the children and granted sole custody to Mother. The Supreme Court vacated the order in part, holding that the trial justice (1) did not abuse her discretion when she denied Defendant's motion to modify custody; and (2) erred in awarding sole custody to Mother without determining that the change of placement was in the best interests of the children. View "Souza v. Souza" on Justia Law

The Supreme Court answered a question certified to it by the United States Bankruptcy Court for the District Court of Rhode Island by holding that R.I. Gen. Laws 9-26-4(11) permits a debtor to claim an exemption for an inherited Individual Retirement Annuity (IRA).Lynette Kapsinow filed a Chapter 7 bankruptcy petition seeking, under Rhode Island law, to exempt an inherited IRA pursuant to section 9-26-4(11). The inherited IRA was inherited by Kapsinow from her late mother. The bankruptcy court certified to the Supreme Court the question about the availability of an exemption in bankruptcy with respect to the inherited IRA. The Supreme Court answered that a debtor may claim an exemption in an inherited IRA, including one inherited from a non-spouse, pursuant to section 9-267-4(11). View "In re Kapsinow" on Justia Law

The Supreme Court affirmed Defendant's conviction of assault with a dangerous weapon in a dwelling house and other offenses, holding that the trial justice did not err in admitting a recording and transcript of a phone call between Defendant and a confidential informant into evidence and did not clearly err by failing to grant a mistrial when it became evidence that defense counsel did not possess or review the complete discovery package prior to trial.Specifically, the Court held (1) the trial justice did not abuse his discretion when he admitted the transcript of the phone call into evidence; (2) there was not clear error in the trial justice's finding that Defendant was not prejudiced by not having certain materials priorate trial; and (3) having found no abuse of discretion when denying the mistrial, there is no reason to overturn the trial justice's denial of a motion for a new trial for the same reasons. View "State v. Rivera" on Justia Law

The Supreme Court affirmed Defendant's conviction of four counts of first-degree sexual assault, holding that the trial justice did not err when he did not declare a mistrial after the prosecutor made "ill advised" statements that were not prejudicial to Defendant.On appeal, Defendant argued that the trial justice erred by failing to grant his motion to pass the case after the prosecutor made an improper remark during her closing argument by briefly referring to the Adult Correctional Institutions (ACI) and after the prosecutor improperly vouched for the credibility of the victim during her closing argument. The Supreme Court affirmed, holding (1) the prosecutor's reference to the ACI was improper, but the comment was not so prejudicial that the trial court's failure to grant a mistrial was an abuse of discretion; and (2) any potential prejudice to Defendant arising from the prosecutor's comment relating her personal experience during her closing argument did not render the proceedings unfair. View "State v. Belen" on Justia Law

In this breach of contract action the Supreme Court affirmed the judgment of the superior court in favor of Defendant, holding that the trial justice did not err in finding that no oral contract existed between the parties.Plaintiff filed a complaint alleging breach of contract, breach of implied contract, and that Defendant was liable under the theories of quasi-contract and promissory estoppel. The trial justice entered judgment in favor of Defendant, finding that no oral or implied-in-fact contract existed between the parties and that Defendant was not liable under the theories of quasi-contract or promissory estoppel. The Supreme Court affirmed, holding that the trial justice did not misconceive or overlook material evidence, did not make factual findings that were clearly wrong, or misapply the law when finding that no oral contract existed between the parties. View "E.W. Burman, Inc. v. Bradford Dyeing Ass'n, Inc." on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Defendant's motion to reduce or correct an illegal sentence, holding that, under the circumstances of this case, the trial court did not err in denying the motion despite the fact that the judgment of conviction did not conform to the oral sentence.In his motion, Defendant conceded that the original sentence imposed was not an illegal sentence but that the error arose from the manner in which the sentence was executed. Specifically, under the law in effect at the time, Defendant was eligible to appear before the parole board after ten years' imprisonment, but it wasn't until eighteen years later that he was first deemed eligible to appear before the parole board. The trial justice denied the motion because Defendant's sentence was not illegal. The Supreme Court affirmed, holding that relief was not available to Defendant. View "State v. Mattatall" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree sexual assault, holding that the trial justice did not abuse its discretion in admitting certain text messages because the evidence was properly authenticated under R.I. R. Evid. 901.The text messages at issue were allegedly sent by Defendant to the complainant. Defendant argued on appeal that because the State did not produce either direct evidence or evidence of distinctive characteristics of the text messages, it did not establish that the text messages were written by Defendant and therefore did not properly authenticate the evidence in accordance with Rule 901. The Supreme Court affirmed, holding that the State produced sufficient circumstantial evidence to establish that Defendant authored the text messages, and therefore, the evidence was properly authenticated under Rule 901. View "State v. Mulcahey" on Justia Law

The Supreme Court affirmed the orders of the superior court dismissing Plaintiff's claims against Defendants, USAA Federal Savings Bank and Charles Baird, for lack of personal jurisdiction, holding that the trial justice was correct in finding that the superior court did not have personal jurisdiction over Defendants.This case stemmed from an alleged oral agreement between Plaintiff and Baird. Plaintiff was a resident of Rhode Island, and Baird was a resident of Florida. Plaintiff filed a complaint against both Baird and USAA, a bank incorporated and based in Texas with whom Baird maintained a personal checking account, seeking to recover certain funds plus consequential damages.The superior court dismissed the case against both defendants for lack of personal jurisdiction. The Supreme Court affirmed, holding (1) the superior court was correct in finding that it did not have either general personal jurisdiction or specific jurisdiction over USAA; and (2) the trial justice was correct in finding that the superior court did not have specific personal jurisdiction over Baird. View "Edward F. St. Onge v. USAA Federal Savings Bank" on Justia Law

The Supreme Court affirmed the decree of the family court terminating Mother's parental rights to her child, holding that the family court did not err when it terminated the rights of Mother, the non-Indian mother of an Indian child who was born suffering from severe medical issues.The trial court terminated Mother's rights after applying the Indian Child Welfare Act (ICWA), finding that the Department of Children, Youth, and Families (DCYF) had met the burden under the ICWA of engaging in active efforts to reunify the child with Mother, and concluding that the child would face serious emotional and physical harm if Mother was given custody of the child. The Supreme Court affirmed, holding that the trial justice did not err when she found that DCYF engaged in "active efforts" to reunify the child with mother as required by the ICWA in section 1912(d). View "In re Roman A." on Justia Law