Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court quashed the order of the district court granting the motion to dismiss filed by the State of Rhode Island, acting by and through the Division of Taxation (Division), in this appeal stemming from a series of transactions for the purchase and sale of gasoline, holding that the district court erred in granting the Division's motion to dismiss based on Plaintiff's failure to exhaust its administrative remedies.The tax at issue was levied on a transaction between Plaintiff and another party and was the subject of several transactions between various entities. Plaintiff reimbursed a third-party for the tax assessed on the sale of 300,000 barrels of gasoline and then initiated this action alleging constitutional violations and violations of the Motor Fuel Tax. The trial judge dismissed the case for Plaintiff's failure to exhaust administrative remedies. The Supreme Court reversed, holding that the trial judge erroneously dismissed the action based on Plaintiff's failure to exhaust its administrative remedies. View "Gunvor USA, LLC v. State, ex rel. Division of Taxation" on Justia Law

The Supreme Court quashed the order of the district court dismissing two actions challenging the State Division of Taxation's denial of Plaintiff's claim for a refund of $4,280,039 paid for Motor Fuel Tax assessed on the purchase and sale of 300,000 barrels of gasoline, holding that the the district court erred.Plaintiff purchased 300,000 barrels of gasoline from Defendant. The Division imposed a motor fuel taxes on the gasoline that was charged to Defendant, as the seller of the gas. Defendant sought reimbursement from Plaintiff, which sought a refund from the Division under R.I. Gen. Stat. 31-36-13. The Division denied Plaintiff's claim for a refund on the grounds that Plaintiff did not have a right to pursue a refund. Plaintiff then filed a complaint alleging constitutional violations and violations of the Motor Fuel Tax, among other claims. Plaintiff then appealed the Division's denial of its request for a refund. The hearing officer concluded that Plaintiff's claim was barred by both res judicata and administrative finality. Ultimately, both cases were dismissed. The Supreme Court quashed the decisions below, holding (1) Plaintiff had standing; (2) the trial judge erred in concluding that res judicata barred Plaintiff's appeal; and (3) the doctrine of administrative finality did not apply to bar Plaintiff's claims. View "Apex Oil Co. v. State, ex rel. Division of Taxation" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of three counts of first-degree sexual assault, following a jury trial, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme eCourt held that the trial justice (1) did not violate Defendant's constitutional right to present a defense by excluding the proposed expert testimony of Dr. Patricia R. Recupero as not relevant under Rule 401 of the Rhode Island Rules of Evidence; (2) did not err in instructing the jury that there was no need for certain testimony to be corroborated in order to support a guilty verdict; and (3) did not abuse his discretion in limiting the redirect examination of Defendant about his preparation for trial. View "State v. Robinson" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Defendant's motion for entry of a judgment of acquittal and convicting him on thirteen counts stemming from his alleged misuse of his position as detective commander in the Middletown Police Department, holding that Defendant's argument on appeal was waived.Defendant was convicted of several counts for assisting an individual to attain a house choice voucher from the Newport Housing Authority. Defendant appealed the denial of his motion for judgment of acquittal on the basis of his contention that "[a]ny rules governing the user's behavior within the system are irrelevant and cannot contribute to the sufficiency of the state's case in a [Sup. Ct. R. Crim. P. 29] motion...." The Supreme Court affirmed, holding that Defendant's argument was waived because it was not the same argument he made below. View "State v. Gamache" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting and committing Defendant on one count of first-degree sexual assault after a jury trial, holding that there was no prejudicial error in the proceedings below.Defendant was convicted after a jury trial and sentenced to thirty-eight years at the Adult Correctional Institutions. On appeal, Defendant challenged the ruling of the trial justice permitting the State to introduce into evidence testimony given by a nurse concerning what the complaining witness told her about the alleged sexual assault. The Supreme Court affirmed, holding (1) Defendant's arguments on appeal were properly before the Court; (2) the was no error in the discretionary decision of the trial justice to admit the nurse's testimony; and (3) certain portions of admitted statements were erroneously admitted, but the evidence was clearly harmless cumulative evidence. View "State v. White" on Justia Law

The Supreme Court affirmed the decision of the superior court dismissing Plaintiffs' claims in favor of Defendants in accordance with Sup. Ct. R. Civ. P. 12(b)(6), holding that the trial court did not err in ruling that R.I. Gen. Laws 9-1-51 (the act), as amended, created a class of criminal actors beyond the scope of actual perpetrators as set forth in the act.Plaintiffs filed separate actions alleging that they were sexually molested as minors by priests at the Roman Catholic Diocese of Providence. Plaintiffs claimed that Defendants' actions rose to the level of criminal aiding and abetting, thus constituting improper conduct. The trial justice granted Defendants' motions to dismiss all claims in all cases, holding that because Defendants were non-perpetrators, the actions were time-barred. The Supreme Court affirmed, holding (1) Defendants could not be found culpable as aiders or abettors; (2) even if Defendants' actions constituted a violation of a criminal statute, they were non-penetrators and the claims were time-barred; and (3) there was no other error. View "Houllahan v. Gelineau" on Justia Law

The Supreme Court affirmed the decree of the family court terminating Mother's parental rights with respect to her daughter (Child), holding that the trial justice did not err in finding by clear and convincing evidence that the Department of Children, Youth, and Families (DCYF) made reasonable efforts to achieve reunification between Mother and Child.DCYF filed a petition to terminate Mother's parental rights on the grounds that she and Father were unfit to parent Child under R.I. Gen. Laws 15-7-7(a)(2)(i) and (a)(3). After a trial, the trial justice granted DCYF petition to terminate Mother's parental rights, determining that DCYF met its burden of proving by clear and convincing evidence that it employed reasonable efforts to achieve reunification. The Supreme Court affirmed, holding that the trial justice did not clearly error or overlook or misconceive material evidence in determining that DCYF made reasonable efforts to achieve reunification. View "In re R.M." on Justia Law

The Supreme Court quashed the decision of the superior court granting Defendant's motion to compel production of a complete, unreacted copy of a settlement agreement between Plaintiffs and the former codefendants who settled Plaintiffs' claims, holding that the trial justice abused her discretion in granting Defendant's motion.In granting Defendant's motion to compel production, the trial justice concluded that the amount paid in accordance with the settlement agreement was not discoverable "pursuant to Rhode Island and federal law." When Plaintiffs failed to comply with the order the superior court granted Defendant's motion to dismiss. The Supreme Court quashed the decision below and remanded the case, holding that the trial justice abused her discretion in granting Defendant's motion to compel production of a complete, unreacted copy of the settlement agreement. View "Noonan v. Sambandam" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of two counts of second-degree sexual assault, holding that the trial justice did not err in denying Defendant's motion to pass the case or his motion for a new trial.Defendant was convicted after a trial. The trial justice denied Defendant's motion for a new trial and sentenced him to eight years of imprisonment for each count, with one year to serve and the remaining time suspended. On appeal, Defendant argued, among other things, that the trial justice abused his discretion in denying Defendant's motion to pass the case due to the prosecutor's allegedly improper comments during closing arguments. The Supreme Judicial Court affirmed, holding (1) the trial justice did not abuse his discretion in denying Defendant's motion to pass the case; and (2) the trial justice did not erroneously admit evidence unduly prejudicial to Defendant, and therefore, Defendant was not entitled to receive a new trial. View "State v. Leonard" on Justia Law

The Supreme Court affirmed in part and vacated in part the amended judgment of the superior court in favor of Plaintiff, as executor of the Estate of Armando Damiani (Mandy) and the Estate of Lillian Estrella, in this action alleging that Defendants had conspired to commit an unlawful conversion of funds in Mandy's investment account, holding that the portion of the amended judgment awarding Plaintiff compensatory damages and prejudgment interest was error.Specifically, the Supreme Court held (1) the trial justice erred by permitting a witness to testify despite knowing that she would invoke her privilege against self-incrimination under the Fifth Amendment, and the error prejudiced Defendant; and (2) there was no reason to disturb the trial justice's decision on Plaintiff's claim for declaratory judgment. View "Estrella v. Janney Montgomery Scott LLC" on Justia Law