Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendant in this construction dispute, holding that summary judgment was appropriate.Plaintiff entered into a contract with a general contractor to construct a facility. The general contractor subcontracted the roofing installation to Defendant. When the roof began to leak, Plaintiff filed a complaint against the general contractor and Defendant, alleging breach of contract, breach of the implied warranty to construct in good and workmanlike manner, misrepresentation, and negligence. The superior court granted Defendant’s motion for summary judgment, holding that Plaintiff was only an incidental beneficiary, as opposed to an intended beneficiary, of the subcontract between Defendant and the general contractor. The Supreme Court affirmed, holding that the motion justice appropriately granted summary judgment in favor of Defendant on Plaintiff’s claims. View "Hexagon Holdings, Inc. v. Carlisle Syntec Inc." on Justia Law

The Supreme Court affirmed Defendant’s conviction of one count of first-degree child molestation sexual assault, holding that none of the superior court justice’s challenged evidentiary rulings warranted reversal.Specifically, the Court held (1) Defendant waived his argument that the trial justice erred in allowing testimony concerning other alleged incidents of sexual assault, in violation of R.I. R. Evid. 403 and 404(b); (2) Defendant failed to preserve his objection to the trial justice’s rulings limiting defense counsel’s cross-examination of a witness, and even if the trial justice erred, such error would have been harmless beyond a reasonable doubt; and (3) Defendant waived his argument that the trial justice erred in allowing hearsay testimony into evidence. View "State v. Colon" on Justia Law

The Supreme Court affirmed Defendant’s conviction of two counts of second-degree child molestation sexual assault, holding that the trial justice did not err in denying Defendant’s motion for a new trial.On appeal, Defendant argued that the evidence presented at trial raised serious doubt about the allegations and that the trial justice overlooked and misconceived material evidence. The Supreme Court disagreed, holding (1) the trial justice conducted an appropriate analysis of the evidence presented, evaluated the credibility of the witnesses, and assessed the weight of the evidence; (2) the trial justice did not err in determining that sufficient credible evidence was submitted to support the verdict on both counts; and (3) therefore, the trial justice did not err in denying Defendant’s motion for a new trial. View "State v. Tabora" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree child abuse, holding that the trial justice did not err by requiring a licensed clinical social worker to testify about statements Defendant made to her while seeking mental-health treatment.A dispositive issue on appeal was whether any privilege arising from the Confidentiality of Health Care Information Act, R.I. Gen. Laws 5-37.3, is abrogated by R.I. Gen. Laws 40-11-11. The Supreme Court affirmed, holding (1) section 40-11-11 unambiguously abrogates all privileges that might otherwise attach to communications between any professional person and her patient in situations involving known or suspected child abuse or neglect; and (2) this nullification of such privileges in judicial proceedings includes criminal proceedings. View "State v. LeFebvre" on Justia Law

The Supreme Court affirmed Defendant’s conviction of reckless driving, holding that the trial justice did not commit clear error or overlook or misconceive material or relevant evidence in denying Defendant’s motion for a new trial.In his motion for a new trial, Defendant argued that the evidence presented at trial was insufficient to convict him of reckless driving and that the jury did not note the specific location where Defendant’s alleged reckless driving took place. The trial justice denied the motion. The Supreme Court affirmed, holding that the trial justice did not clearly err or misconceive material evidence and did not err in denying Defendant’s motion for a new trial. View "State v. Silva" on Justia Law

The Supreme Court affirmed the judgment of the superior court dismissing Plaintiff’s probate court appeals for his failure to comply with several court orders, holding that the superior court justice properly exercised his discretion in dismissing Plaintiff’s appeals.Ostensibly acting as successor executor for the wills of two former clients, Appellant challenged probate court orders relating to guardianship decrees. The superior court dismissed Appellant’s five probate court appeals for Appellant’s failure to comply with the court’s orders. The Supreme Court affirmed, holding (1) the superior court justice did not abuse his discretion; and (2) because Appellant’s representations to the probate courts, the superior court, and the Supreme Court were not as forthcoming as the rules of procedure require, the case is remanded to allow Defendants an opportunity to file a motion for sanctions if they so choose. View "Malinou v. Neri" on Justia Law

The Supreme Court vacated the judgment of the superior court entering judgment in favor of Defendant on Plaintiff’s claim that Defendant terminated her employment in violation of the Fair Employment Practices Act (FEPA), holding that Plaintiff complied with the statutory requirements for commencing a FEPA violation action in superior court.Defendant moved to dismiss Plaintiff’s complaint on the basis that, as to the FEPA claim, Plaintiff had not properly and timely requested a right-to-sue letter from the Rhode Island Commission for Human Rights as required by R.I. Gen. Laws 28-5-24.1. The Commission intervened. The hearing justice granted Defendant’s and the Commission’s motions to dismiss, concluding that Plaintiff had not timely requested a right-to-sue letter. The Supreme Court vacated the judgment below, holding that, based on the circumstances of this case, Plaintiff complied with the requirements of section 28-5-24.1 for bringing this FEPA action. View "Mokwenyei v. Rhode Island Hospital" on Justia Law

The Supreme Court affirmed the judgment of the superior court finding Defendant guilty of one count of second-degree murder and one count of discharging a firearm while committing a crime of violence, holding that the trial justice did not err in denying Defendant’s motion to suppress or in failing to exclude certain evidence.Specifically, the Court held (1) law enforcement’s failure to comply with Miranda does not require the suppression of the physical evidence acquired as a result of a suspect’s unwarned, but voluntary, statements; (2) Defendant’s statements leading detectives to a firearm and ammunition were voluntary, and therefore, the gun and ammunition were admissible; and (3) the trial justice did not err in concluding that the police’s seizure through the impounding of Defendant’s vehicle and the subsequent search of the vehicle were constitutional, and therefore, the evidence obtained therein admissible. View "State v. Beauregard" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Appellant’s application for postconviction relief, holding that Appellant was not entitled to postconviction relief.Appellant was found guilty of murder in the first degree and other offenses and sentenced to life imprisonment. Appellant later filed the instant application for postconviction relief alleging that he was denied effective assistance of trial and appellate counsel. After a hearing, the hearing justice denied the application for postconviction relief. The Supreme Court affirmed, holding that there was no ineffective assistance of either Appellant’s trial or appellate counsel, and therefore, the hearing justice properly denied Appellant’s application for postconviction relief. View "Jimenez v. State" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of second-degree sexual assault for having sexually assaulted a fifteen-year-old neighbor, holding that the trial justice did not commit reversible error.Specifically, the Court held (1) the trial justice did not commit reversible error by sustaining the prosecutor’s objection to defense counsel’s question to the complainant as to whether he had received any professional counseling with respect to the events at issue in this case; (2) Defendant waived his argument that the trial court erred in not striking Defendant’s wife’s response to the prosecutor’s questions about contacting the complainant or his family; and (3) the trial justice did not err in overruling the defense objection to Defendant’s wife’s testimony that she and Defendant lived on the side of an elementary school. View "State v. MacNeil" on Justia Law