Justia Rhode Island Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the superior court dismissing Appellant's probate appeal after finding that, because Appellant was under guardianship, he lacked the capacity to retain legal counsel and file an appeal to the superior court in his own name, holding that the superior court properly dismissed Appellant's appeal on the ground that Appellant lacked the capacity to bring and maintain an action in his own name.On appeal, Appellant argued that the superior court erred in dismissing his probate appeal because he was only under a limited guardianship and was thus entitled to pursue the probate appeal on his own. The Supreme Court affirmed, holding that Appellant was not under a limited guardianship, but, rather, a full guardianship, and did not retain the right to pursue this action on his own behalf. View "In re Estate of Amet Chelo" on Justia Law

The Supreme Court affirmed the order of the superior court denying Defendant's motion to confirm an arbitration award in Defendant's favor, holding that the trial justice properly exercised his discretion when he determined, under the circumstances, that Plaintiff's corrected electronic filing rejecting the arbitration award was prompt.In the underlying legal malpractice action Plaintiff alleged that Defendant, his former attorney, had failed properly to record a property settlement agreement that had been executed by Plaintiff and his ex-wife during the course of their divorce proceeding. The action proceeded to arbitration, and an arbitration award was issued in favor of Defendant. Plaintiff rejected the arbitration award using the superior court's electronic filing system but used an incorrect filing code. When Plaintiff learned of his error he attempted a correct filing. That filing was rejected because the statutory filing period had expired. The Supreme Court affirmed the superior court's denial of Defendant's motion to confirm the arbitration award, holding that Plaintiff's correct filing was properly considered timely. View "Richard v. Robinson" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree child molestation sexual assault, holding that the trial justice did not commit clear error in the proceedings below.On appeal, Defendant argued that the trial justice committed clear error by (1) refusing to suppress his statement to the police because the confession was not knowing, intelligent or voluntary, and (2) admitting Defendant's confession into evidence despite Defendant's invocation of his right to remain silent. The Supreme Court affirmed, holding (1) the trial justice did not err in concluding that Defendant's statements to the police were knowing, intelligent, and voluntary; and (2) the trial justice did not err in denying Defendant's motion to suppress his statements to the police during his interrogation. View "State v. Munir" on Justia Law

The Supreme Court vacated the judgments of the superior court granting summary judgment in favor of the defendant and the third-party defendant (collectively, Defendants) on Plaintiff's complaint alleging negligence for her injuries and the third-party complaint seeking to defend, indemnify, and hold the third-party defendant harmless for claims arising out of the third-party defendant's duty under Defendants' snow services agreement, holding that genuine issues of material fact existed precluding summary judgment.Specifically at issue before the trial justice was whether there were genuine issues of material fact as to the dangerous condition that caused Plaintiff's fall that would preclude summary judgment. The trial justice weighed the evidence before her at least twice during the summary judgment hearing. The Supreme Court vacated the superior court's judgments, holding that the trial justice improperly weighed the evidence before her at the summary judgment hearing. View "Voccola v. Stop & Shop Supermarket Co." on Justia Law