Justia Rhode Island Supreme Court Opinion Summaries

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

In this case concerning the award of a concessions contract for concessions at a public park in the City of Providence the Supreme Court affirmed the judgment of the superior court in favor of Defendants - the City, the Rhode Island Zoological Society (the Zoo), P.G.S., Inc., and various municipal officials - holding that the trial justice did not abuse his discretion or commit a clear error of law.Plaintiff brought this complaint after the City awarded the concessions contract to the Zoo rather than to Plaintiff, La Gondola, Inc. The trial justice entered judgment for Defendants. The Supreme Court affirmed, holding that the trial justice properly (1) concluded that the bidding process was free of corruption, bad faith, and/or an abuse of discretion; (2) held that a certain amendment to the contract was not enforceable; and (3) denied Plaintiff's claim of intentional interference with prospective contractual relations. View "La Gondola, Inc. v. City of Providence" on Justia Law

In this dispute surrounding the distribution of the assets of the parties' deceased mother the Supreme Court affirmed the judgments of the superior court with respect to the substance of two orders of the probate court, holding that two bank accounts should be distributed pursuant to paragraph three of the decedent's will and that there was no basis to remove the current executrix of the decedent's estate.The decedent's children were Michaela, Mark, Lizbeth, and Lisa. Lizbeth was named executrix of the decedent's estate. The probate court determined that the two accounts at issue were part of the "general inventory" of the estate and, therefore, the proceeds of those accounts should be distributed under paragraph six of Catherine's will - i.e., divided equally among all four of Catherine's children. Lizbeth appealed. When Michaela and Mark unsuccessfully sought to remove Lizabeth as executrix, they appealed. The two appeals were consolidated. The superior court concluded that the accounts were not estate assets and, pursuant to paragraph three of the decedent's will, should be distributed to Lisa and Lizbeth respectively. The court affirmed the probate court's decision not to remove Lizabeth as executrix. The Supreme Court affirmed both judgments of the superior court, holding that the trial justice did not err in its judgment. View "Larkin v. Arthurs" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Appellant's application for postconviction relief, holding that the postconviction hearing justice did not err in denying Appellant's application.Twelve years after Appellant entered a nolo contendere plea to the charge of possession of cocaine Appellant filed an application for postconviction relief alleging, among other things, that he received ineffective assistance of counsel because he was not advised of the immigration consequences of his plea. The postconvcition hearing justice denied the application and declined to address the State's issue of laches. The Supreme Court affirmed, holding that Appellant's arguments on appeal lacked merit and that Appellant's petition for postconviction relief could also have been denied based on the doctrine of laches. View "Desamours v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of assault of a police officer, resisting arrest, and disorderly conduct, holding that the trial justice did not err in determining that Defendant had waived his constitutional right to counsel.On appeal, Defendant argued that the trial justice erred in concluding that he made a voluntary, knowing, and intelligent waiver of his constitutional right to counsel. The Supreme Court disagreed, holding that the trial justice did not err in (1) determining that Defendant voluntarily waived his right to counsel prior to trial; and (2) finding that Defendant knowingly and intelligently waived his right to counsel. View "State v. Souto" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendants on the grounds that the case was moot, holding that there was no justiciable controversy before the Court and that Plaintiffs failed to meet the burden of demonstrating that the issues raised in their complaint were of extreme public importance and were capable of repetition yet will evade review.After the National Education Association Rhode Island and the Middletown Teachers' Association/NEA (collectively, the Union) and the Middletown School Committee (school committee) reached a tentative successor agreement to a collective bargaining agreement (CBA) that was due to expire the Town of Middletown refused to ratify the agreement. The Union filed suit challenging the denial. Thereafter, the parties agreed to a new three-year CBA, and the Town voted to ratify the agreement. The trial justice granted summary judgment for Defendants, the Town, the school committee, and the Middletown School Department. The Supreme Court affirmed, holding that the trial justice did not err in granting summary judgment on the basis of mootness and that no exceptions to the mootness doctrine existed. View "National Education Ass'n Rhode Island v. Town of Middletown" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Defendant on the ground that Plaintiff was not legally entitled to recover rent monies which he had paid to Defendant over the period of time during which he was renting a waterfront condominium from her while she was in violation of R.I. Gen. Laws 34-18-22.3, holding that the hearing justice properly granted Defendant's motion for summary judgment.Plaintiff sought retroactive recovery of rent paid to Defendant because Defendant had not complied with section 34-18-22.3, which requires a landlord who is not a resident of the state to designate an in-state agent for service of process. The superior court granted summary judgment for Defendant. The Supreme Court affirmed, holding (1) Plaintiff was not allowed to recover from Defendant for her alleged violation of section 34-18-22.3 because he failed to show that he suffered harm as a result of Defendant's violation; (2) because Plaintiff did not incur any damages as a result of Defendant's alleged offense, there was no basis for recovery under R.I. Gen. Laws 9-1-2; and (3) the trial justice did not err when he determined that the elements of unjust enrichment were not satisfied based on the facts of this case. View "Olsen v. DeMayo" on Justia Law

The Supreme Court affirmed the superior court's judgment ruling in favor of Plaintiff, Management Capital, LLC, on its complaint filed after Defendant, F.A.F., Inc., maintained that a common stock warrant held by Management had no value, holding that the superior court did not err in its judgment.Specifically, the Court held that trial justice did not err when he (1) reformed certain dates in a stock warrant that he found were a result of mutual mistake; (2) determined that “funded debt” was an unambiguous term meaning “long-term debt”; (3) found that FAF repudiated its obligations under the stock warrant; (4) found that Management properly preserved its post-repudiation rights; (5) determined that Management proved its damages with reasonable certainty; and (6) determined that prejudgment interest accrued beginning on October 13, 2008. View "Management Capital, LLC v. F.A.F., Inc." on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder by use of a firearm he was not licensed to carry, holding that Defendant was not entitled to relief on any of his allegations of error.Specifically, the Court held (1) the trial justice did not err by denying Defendant's pretrial motion to suppress statements he gave to the police in the first of two interrogations; (2) Defendant failed to show that his trial counsel had an actual conflict of interest throughout her representation of him; (3) Defendant waived his argument that the trial court erred in admitting testimonial and photographic evidence suggesting Defendant's affiliation with known gangs; and (4) Defendant waived direct appellate review of challenged jury instructions. View "State v. Andrade" on Justia Law