Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the plan administrator denying Plaintiff pension benefits, holding that the superior court did not err in granting Defendants’ motion to dismiss for lack of subject-matter jurisdiction and in alternatively granting summary judgment in favor of Defendants.Plaintiff requested pension benefits but Defendants denied the request. Plaintiff then filed a complaint for breach of contract as well as seeking a declaratory judgment against Defendants. The hearing justice ultimately determined that the court lacked subject-matter jurisdiction over Plaintiff’s claim and granted Defendants’ motion for summary judgment. The Supreme Court affirmed the superior court’s judgment regarding its lack of subject matter jurisdiction and reinstated and granted Plaintiff’s previously-denied petition or writ of certiorari, consolidated that matter with the present appeal, and affirmed the decision of the plan administrator denying Plaintiff pension benefits, holding that the plan administrator’s decision was sufficiently supported by testimonial and other evidence that that it reached a reasonable conclusion. View "Sullivan v. Coventry Municipal Employees’ Retirement Plan" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Defendants on Plaintiffs’ negligence and nuisance claims, holding that there was no error in the proceedings below.In their complaint, Plaintiffs alleged that an underground pipe emptied water from Defendants’ property onto a portion of Plaintiffs’ property in such a way that the flow of water from the pipe was actionable as a matter of both negligence and nuisance law. The trial justice entered a decision favorable to Defendants. The Supreme Court affirmed, holding that there was no clear error in the trial justice’s conclusion that Plaintiffs failed to prove that they suffered any harm. View "Silva v. Laverty" on Justia Law

The Supreme Court affirmed the order of the superior court entering summary judgment in favor of Defendant on Plaintiff’s complaint alleging breach of contract and fraud, holding that the hearing justice correctly granted Defendant’s motion for summary judgment after concluding that Plaintiff’s complaint was barred by the relevant statute of limitations.In his complaint, Plaintiff argued that Defendant breached his fiduciary duty owed to Plaintiff. The hearing justice concluded that the complaint was subject to the three-year statute of limitations for legal malpractice contained within R.I. Gen. Laws 9-1-14.3 and concluded that Plaintiff’s cause of action was untimely. The Supreme Court affirmed, holding that Plaintiff’s complaint was time barred. View "Broccoli v. Manning" on Justia Law

In this complaint brought against Rhode Island College and various college officials alleging that Defendants’ conduct toward Plaintiff during his enrollment in the Master of Social Work program due to his political beliefs violated his constitutional rights the Supreme Court vacated in part and affirmed in part the judgment of the hearing justice granting summary judgment in favor of Defendants and dismissing Plaintiff’s claim for punitive damages, holding that summary judgment must be vacated as to certain counts.Specifically, the hearing justice held that Defendants were entitled to summary judgment on Plaintiff’s claims that Defendant violated his constitutional rights to freedom of expression and equal protection, conspired to violate his civil rights, and violated his procedural due process rights. The hearing justice also found that Plaintiff had not established a prima facie case for punitive damages. The Supreme Court held (1) summary judgment was improper as to Plaintiff’s freedom of speech claims; (2) summary judgment was proper as to Plaintiff’s equal protection and procedural due process claims; (3) Defendants were entitled to judgment as a matter of law on Plaintiff’s conspiracy claim; and (4) the hearing justice properly found that Plaintiff had not met his burden to demonstrate a prima facie case for punitive damages. View "Felkner v. Rhode Island College" on Justia Law

The Supreme Court affirmed the entry of summary judgment in favor of Dr. Shea Gregg in this wrongful death action, holding that the superior court correctly found that the statutory period for filing a wrongful death action had expired.Plaintiff filed a second amended complaint against a hospital and physicians, including Dr. Gregg, that had been involved in the decedent’s care, alleging negligent treatment leading to the wrongful death of the decedent. Dr. Gregg filed a motion for summary judgment asserting that the statute of limitations for wrongful death had expired before he had been added as a defendant. The superior court agreed and granted the motion. Thereafter, judgment was entered in favor of Dr. Gregg. The Supreme Court affirmed, holding that Plaintiff’s wrongful death claim against Dr. Gregg was time barred. View "Parrillo v. Rhode Island Hospital" on Justia Law

The Supreme Court affirmed the order of the family court denying a miscellaneous petition filed by Plaintiff pursuant to R.I. Gen. Laws 15-5-24.1 and 15-5-24.3 for grandparent visitation with two children of her daughter, who was deceased, holding that the hearing justice was within his discretion in denying Plaintiff’s petition.Defendant, who was previously married to Plaintiff’s daughter, was the biological father of the two children at issue in this case and had full custody of the children. Plaintiff filed this petition seeking grandparent visitation alleging that Defendant had refused her visitation requests. The hearing justice denied Plaintiff’s petition. The Supreme Court affirmed, holding that the hearing justice did not abuse his discretion in denying Plaintiff’s petition for grandparent visitation. View "MacTavish-Thurber v. Gauvin" on Justia Law

In this case arising from a dispute arising from the parties’ lease agreement, the Supreme Court vacated the order of the superior court denying Defendant’s motion to stay litigation in favor of arbitration, holding that the parties failed to resolve their dispute through amicable mutual discussions pursuant to an arbitration clause in their agreement, and therefore, their dispute was ripe for arbitration.Plaintiffs leased from Defendant a parcel of land for the purposing of building and maintaining a building. Construction was never commenced, and Plaintiffs demanded that Defendant restore the property to its former condition. Plaintiffs later filed a complaint seeking a declaratory judgment that Defendant was in breach of the lease. Defendant moved for a stay of litigation, arguing that the arbitration clause in the lease required that all disputes be resolved by arbitration. The hearing justice denied the motion, concluding that the lease’s arbitration clause applied only to disputes that did not involve an alleged breach of the lease. The Supreme Court disagreed, holding (1) the language of the agreement provided that alleged breaches of the lease were to be arbitrated provided that the parties attempted and failed to resolve those disputes through mutual discussions; and (2) because the parties attempted conciliation, their dispute was ripe for arbitration. View "Rhode Island Council on Postsecondary Education v. Hellenic Society Paideia - Rhode Island Chapter" on Justia Law

In this action involving various allegations against the former mayor of the City of Central Falls, the Supreme Court affirmed the decision of the superior court granting summary judgment in favor of Defendant, the Rhode Island Interlocal Risk Management Trust, holding that summary judgment was properly granted.Specifically, the Supreme Court held (1) the complex nature of the case did not preclude the hearing justice from considering the Trust’s summary judgment motions; (2) res judicata did not bar new claims made by two plaintiffs, but those claims were barred by the pertinent statute of limitations; and (3) regarding old claims brought by the same two plaintiffs, the hearing justice did not err in granting summary judgment on Plaintiffs’ claims for intentional infliction of emotional distress, public disclosure of private facts and false light, and defamation. View "Shannahan v. Moreau" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendant, Pare Engineering Corporation, on John Rocchio Corporation’s action asserting claims for interference with prospective contractual relations, negligence, and breach of contractual obligations due to Rocchio as a third-party beneficiary of the contract between Pare and the Warwick Sewer Authority (WSA), holding that summary judgment was properly granted.The WSA entered into an agreement with Pare for consulting and engineering services relating to a sewer infrastructure expansion project planned by the WSA. Pare provided requests for proposal that would serve as the basis for the biding process for potential general contractors. Rocchio was the low bidder, but the contract was awarded to another bidder. Rocchio then brought this action. The hearing justice granted Pare’s motion for summary judgment. The Supreme Court affirmed, holding that summary judgment was appropriate on all claims. View "John Rocchio Corp. v. Pare Engineering Corp." on Justia Law

The Supreme Court vacated the judgment of conviction after a jury found Defendant guilty of first degree sexual assault and murder, holding that Defendant was entitled to a new trial because the trial court violated the Confrontation Clause.In this cold case, Defendant was charged with the crimes for which he was convicted twenty-five years after the victim was murdered. On appeal, Defendant argued, among other things, that the trial justice erred by allowing statements of deceased declarants to be admitted into evidence, in violation of the Confrontation Clause. The Supreme Court agreed and vacated Defendant’s convictions, holding (1) the Confrontation Clause was violated when the State implicitly conveyed to the jury the content of statements made by deceased witnesses, both through a detective’s testimony and the closing argument of the prosecutor; and (2) these violations were not harmless beyond a reasonable doubt. The Court remanded the case to the superior court for a new trial. View "State v. Roscoe" on Justia Law