Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the report and order of the Public Utilities Commission (PUC) denying the Town of Portsmouth’s request for a discounted rate for ferry service from the Town of Bristol to Prudence Island for municipal vehicles and passengers performing essential government services, holding that the PUC did not err in denying the Town’s request for a discounted rate.On appeal, the Town argued that the PUC’s express statutory authority and implied powers grant it the right to order the Town’s requested rates without needing the permission of the entity it regulates, i.e., A&R Marine Corp., d/b/a Prudence & Bay Islands Transport. The Supreme Court disagreed, holding (1) before the PUC would have been legally authorized to act upon a discounted ferry rate for the Town, it would have been necessary, pursuant to R.I. Gen. Laws 39-2-5(2), for A&R Marine to propose such a discounted rate; and (2) because A&R never made such a proposal, the PUC’s report and order is affirmed. View "In re A&R Marine Corp." on Justia Law

The Supreme Court affirmed the trial justice's judgment in favor of Summit Insurance Company in this declaratory judgment action seeking to clarify Summit’s liability for prejudgment interest and damages above the policy limits set forth in Summit’s automobile insurance contract with its insured, Eric Stricklett, holding that Summit owed no duty to Scott, John, and Cathy Alves.A car operated by Stricklett struck and injured Scott Alves. Stricklett’s vehicle was insured by Summit under a policy with a $25,000 per person, $50,000 per accident coverage limit. The Alveses sent Scott’s hospital bills to Summit, but Summit informed the Alveses that it had determined that Stricklett was not at fault for Scott’s injuries. The Alveses later made a settlement demand of $300,000 to Summit. Summit offered its policy limits on behalf of Stricklett, but the Alveses rejected the offer. Summit then filed this action requesting that the court determine whether Summit had an obligation to pay any sums beyond its policy limits. The trial justice granted judgment in favor of Summit. The Supreme Court affirmed, holding that the duty of an insurer to affirmatively settle an insurance claim on behalf of its insured does not apply with equal force to third-party claimants in the form of a duty of good faith and fair dealing. View "Summit Insurance Co. v. Stricklett" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of three counts of assault with a dangerous weapon, three counts of discharging a firearm while committing a crime of violence, and one count of carrying a pistol without a license, holding that there was no error or abuse of discretion in the proceedings below.On appeal, Defendant asked the Supreme Court to grant him a new trial on three grounds. The Supreme Court denied relief and affirmed the convictions, holding (1) Defendant waived his argument that the State untimely disclosed the identity of two witnesses who were placed in witness protection; (2) the trial justice did not err in admitting into evidence prior inconsistent statements made to the police by one witness; and (3) the trial justice properly denied Defendant’s motion for a new trial. View "State v. Stokes" on Justia Law

The Supreme Court affirmed the order of the superior court denying Defendant’s motion to correct his sentence, holding that there was no error on the part of the hearing justice in denying Defendant’s motion to correct his sentence.Defendant pled nolo contendere to domestic murder in the first degree and agreed to habitual offender status in exchange for the dismissal of other counts against him. Defendant was sentenced to life on the domestic murder count and to ten to fifteen years as a habitual offender. On appeal, Defendant argued that his plea agreement was illegal because, as to his habitual offender sentence, the sentencing justice did not set a particular date when Defendant would be eligible for parole. The Supreme Court denied relief, holding that the hearing justice did not err in denying Defendant’s motion to correct his sentence because the statutory language does not require that a sentencing justice set a particular date when a defendant will be eligible for parole. View "State v. Paiva" on Justia Law

The Supreme Court affirmed the judgments of the superior court adjudging Appellant to be a violator of his probation, holding (1) there was no reason to remand Appellant’s case for a new probation violation hearing under the new standard set forth in accordance with the amended Rule 32(f) of the Superior Court Rules of Criminal Procedure; and (2) the hearing justice did not act arbitrarily or capriciously in finding that Appellant had violated the conditions of his probation.Five years after the judgments of conviction and commitment were entered, Appellant filed petitions for the issuance of writs of certiorari, which the Supreme Court granted. The Court then affirmed the judgments of the superior court, holding (1) the judgments at issue were final in 2016 when Rule 32(f) was amended, and they remained final; and (2) the evidence was sufficient to support the hearing justice’s conclusion that Appellant had breached the terms and conditions of his probation. View "State v. D’Amico" on Justia Law

The Supreme Court affirmed the orders of the superior court granting the City of Pawtucket’s motion to dismiss Appellant’s motion to vacate an arbitration award issued in connection with the termination of Appellant’s employment as a firefighter with the City and denying Appellant’s motion to substitute a union as the proper plaintiff, holding that the superior court committed no error.After the City terminated Appellant’s employment, the Union filed a grievance against the City challenging the termination. The matter proceeded to arbitration, and the arbitrator rendered a decision finding in favor of the City. Appellant timely filed a motion in the superior court seeking to vacate the arbitration award and moved to amend his pleading to substitute the Union as a proper party. The hearing justice denied Appellant’s motion to substitute and granted the City’s motion to dismiss. The Supreme Court affirmed, holding (1) Appellant had no individual standing to bring a motion to vacate the arbitrator’s award; and (2) the hearing justice acted within her discretion in denying Appellant’s motion to amend. View "Gannon v. City of Pawtucket" on Justia Law

The Supreme Court affirmed the decision of the superior court granting summary judgment in favor of Plaintiff, holding that summary judgment was appropriate because the mortgage granted to Defendant was discharged by operation of the ancient mortgages statute, Mass. Gen. Laws 34-26-7, well before the commencement of foreclosure proceedings in 2017.On appeal, Defendant argued that it held a valid mortgage on the property on which Defendant commenced foreclosure proceedings. The Supreme Court affirmed the judgment of the superior court, holding that the hearing justice did not err in granting Plaintiff’s motion for summary judgment because Defendant’s mortgage on the property was discharged by operation of the ancient mortgages statute before the foreclosure proceedings commenced. View "Bayview Loan Servicing, LLC v. Providence Business Loan Fund, Inc." on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree robbery, conspiracy to commit first-degree robbery, and assault with a dangerous weapon in a dwelling house with intent to commit robbery, holding that the trial justice was not clearly wrong when he denied Defendant’s motion for a new trial.After a jury trial, Defendant was convicted. The trial justice denied Defendant’s renewed motion for judgment of acquittal and motion for new trial, in which Defendant argued that the jury’s verdict was contrary to the weight of the evidence. The Supreme Court affirmed the trial justice’s denial of Defendant’s motion for new trial, holding that the trial justice did not overlook or misconceive any material evidence and did not err in denying the motion. View "State v. Johnson" on Justia Law

The Supreme Court quashed the order of the superior court denying Plaintiff’s motion for a protective order concerning the deposition of Lawrence Rainey, holding that, pursuant to rule 26(b)(4)(B) of the Superior Court Rules of Civil Procedure, Defendants failed to demonstrate “exceptional circumstances” to depose Rainey, a nontestifying expert.On appeal, Plaintiff argued that Rainey was a nontestifying expert and therefore may not be deposed absent a showing of exceptional circumstances in accordance with Rule 26(b)(4)(B). The Supreme Court agreed, holding (1) Rule 26(b)(4)(B) is applicable to the discovery issue here; (2) the hearing justice erred in failing properly to apply the Rule 26(b)(4)(B) standard in this case; and (3) Defendants failed to demonstrate “exceptional circumstances” as to why they wished to depose Rainey. View "Sandy Point Farms, Inc. v. Sandy Point Village, LLC" on Justia Law

The Supreme Court quashed the judgment of the superior court that granted Defendant’s application for postconviction relief and reinstated Defendant’s convictions, holding that the hearing justice erred in holding that trial counsel rendered ineffective assistance in certain respects.The Supreme Court reinstated Defendant’s conviction with respect to aiding-and-abetting counts for felony murder, robbery, using a firearm in the commission of a crime o violence, discharging a firearm in the commission of a crime of violence, and committing a crime of violence while armed and having available a firearm. Specifically, the Supreme Court held (1) trial counsels’ performance was not deficient in failing to propose aiding-and-abetting jury instructions in line with Rosemond v. United States, 572 U.S. 65 (2014), because that case was inapplicable here; and (2) the hearing justice erred when she held that trial counsel rendered ineffective assistance by failing to challenge the sufficiency of the evidence with respect to an aiding-and-abetting theory. View "Whitaker v. State" on Justia Law