Justia Rhode Island Supreme Court Opinion Summaries

In this personal injury suit seeking damages for injures alleged to be caused by defects in a public park, the Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of the City of East Providence, holding that the City was immune from liability under the Recreational Use Statute, R.I. Gen. Laws chapter 6 of title 32 (RUS).Plaintiff was injured while riding his bicycle through Glenlon Park, located in East Providence. Plaintiff brought this action claiming that Defendant was negligent in maintaining the park. Defendants moved for summary judgment, arguing that the City was immune from liability under the RUS because the park was open to the public for recreational purposes and the City did not act in a willful or malicious manner in failing to guard or warn against a known danger. The superior court granted summary judgment for the City. The Supreme Court affirmed, holding (1) the City was immune from liability under the RUS; (2) the spoliation doctrine did not apply to the circumstances presented in this case; and (3) the superior court did not err in refusing to apply the exception to the RUS, R.I. Gen. Laws 32-6-5(a)(1), to Plaintiff's claim. View "Yattaw v. City of East Providence" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree murder, holding that Defendant waived his argument that the trial justice erred when she failed to instruct the jury on the lesser-included offense of voluntary manslaughter and that the trial justice did not err in refusing to grant a mistrial.Specifically, the Court held (1) Defendant's contention that the trial judge erred in failing to give the jury an instruction on voluntary manslaughter and instead giving an involuntary manslaughter instruction was not properly preserved for appellate review; (2) the trial justice did not err in refusing to declare a mistrial on what Defendant characterized as the prosecutor's "wholly improper" statements made during closing argument because the court's cautionary instruction cured the prejudice created by the prosecutor's comments labeling Defendant as a scam artist, liar, and thief. View "State v. Lastarza" on Justia Law

The Supreme Court affirmed Defendant's conviction of four counts of first-degree child molestation sexual assault, holding that Defendant was not entitled to a new trial based on any of his arguments on appeal.Specifically, the Court held (1) the trial justice did not err when he accepted a jury waiver form that Defendant had signed outside the presence of the trial justice; (2) Defendant's colloquy with the trial justice demonstrated that Defendant knowingly, intelligently, and voluntarily waived his right to a jury trial; and (3) the trial justice adequately explained the differences between a jury trial and a bench trial. View "State v. Morais" on Justia Law

In this negligence case, the Supreme Court affirmed the judgment of the superior court entering judgment for Feeley & Driscoll, P.C. (Feeley) on all claims by The Rhode Island Industrial-Recreational Building Authority (IRBA), holding that Feeley did not owe a duty of care to IRBA.The hearing justice concluded that, under the "Restatement Rule," Feeley, an accounting firm, did not owe a duty of care to IRBA as a third party with respect to what IRBA alleged was a negligently prepared report by Feeley that IRBA alleged it relied upon. The Supreme Court affirmed, holding (1) the Restatement Rule is the most sensible approach to the question of the extent of potential liability to third parties to which an accountant/auditor should be exposed for alleged negligence on his or her part, and thus the moderate approach provided for in the Restatement Rule is hereby adopted; and (2) when the Restatement Rule is applied to the instant case, the hearing justice did not err in holding that Feeley did not err in holding that Feeley owed no duty to IRBA. View "Rhode Island Industrial-Recreational Building Authority v. Capco Endurance, LLC" on Justia Law

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