Justia Rhode Island Supreme Court Opinion Summaries

In this property dispute, the Supreme Court affirmed the judgment of the superior court denying Plaintiffs’ claims in whole and denying Defendants’ request for attorneys’ fees.When Defendants fenced the confines of an easement that was created by a settlement agreement and consent order entered by the superior court, Plaintiffs filed suit claiming that Defendants’ actions frustrated what they contended was the intended purpose of the consent order. The trial justice denied relief as to all of Plaintiffs’ claims. At a subsequent hearing, the trial justice denied Defendants an award of attorneys’ fees. The Supreme Court affirmed, holding that there was no abuse of discretion in the trial justice’s rulings. View "Arnold v. Arnold" on Justia Law

The Supreme Court vacated Defendant’s convictions on count four, sex trafficking of a minor, in violation of R.I. Gen. Laws 11-67-6, and count six, conspiring to commit the crime of sex trafficking with a minor, holding that a gap in the language of section 11-67-6 rendered it unenforceable.Specifically, the Supreme Court held that the gap in section 11-67-6(b) was a statutory flaw that could not be repaired without the addition of language that criminalizes the conduct described in the statute, which is a task that goes beyond statutory construction. Therefore, the Court held that section 11-67-6 failed to state a crime, and therefore, Defendant’s motion to dismiss counts four and six of the indictment should have been granted. The dissent would affirm the convictions on counts four and six, holding that the statute did not involve the son of legislative commission that required a reversal of Defendant’s conviction because the statute, “for all its lack of absolute perfection in terms of draftsmanship,” sufficed to give fair and adequate notice. View "State v. Maxie" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying the motion brought by Plaintiff, SMS Financial XXV, LLC, for summary judgment and granting the cross-motion for summary judgment brought by Defendants, David Corsetti and 385 South Main Street, LLC, on Plaintiff’s suit alleging that Defendants breached the terms of a promissory note.In the cross-motion for summary judgment, Defendants asserted that Plaintiff was unable to enforce or collect upon the note because the note had been lost. The hearing justice granted Defendants’ cross-motion for summary judgment. The Supreme Court affirmed, holding (1) under the plain language of R.I. Gen. Laws 6A-3-309(a) Plaintiff was not entitled to enforce the note because the note was in the possession of the original holder of the note when it was lost, not Plaintiff, to whom the original holder assigned its interest; and (2) pursuant to the statute, Plaintiff was not entitled to enforce the note’s provision mandating that Defendants issue a replacement note. View "SMS Financial XXV, LLC v. Corsetti" on Justia Law

The Supreme Court affirmed the order of the family court denying Mother’s motion to relocate with the parties’ four minor children from Rhode Island to Australia, holding that the hearing justice did not overlook or misconceive material evidence in reaching his decision, nor were his factual findings clearly wrong.After a hearing on Mother’s motion, the hearing justice concluded that relocation would not be in the children’s best interests. The Supreme Court affirmed, holding that there was no reason to disturb the ruling of the hearing justice that relocation of the minor children to Australia would not be in their best interests. View "Ainsworth v. Ainsworth" on Justia Law

In this dispute over a strip of real property in the Town of Coventry the Supreme Court affirmed the judgment of the hearing justice issuing declaratory judgment in Plaintiffs’ favor after having granted Plaintiffs’ motion for summary judgment, holding that the hearing justice did not err in the proceedings below.The Town argued that the real property had been dedicated to the Town as a public street in 1946. The hearing justice determined that, even assuming for the sake of deciding that there had been a dedication, there was nothing to support the Town’s position that the dedication was accepted either by public use or by official action. The Supreme Court affirmed, holding (1) because the Town explicitly conceded that there had been no acceptance of the purported offer of dedication of the strip of land, the hearing justice did not err in granting summary judgment for Plaintiffs on that basis; and (2) there was no completed dedication of the strip of property because the Town failed to accept the purported offer of dedication within a reasonable period of time and thereby forfeited its right to accept that purported offer. View "Ucci v. Town of Coventry" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment for Defendant, Chase Bank USA, N.A., on Plaintiff’s claims alleging that Chase agreed to issue him two new loans to pay promissory notes secured by mortgages on his two properties, but that Pasquale Scavitti III, whom Chase engaged as its closing agent, converted the loan proceeds for his own use and failed to disburse them.The hearing justice determined that summary judgment was appropriate because, even if Scavitti were Chase’s agent, there was no genuine issue of material fact as to whether Scavitti’s conduct was within the scope of the purported agency relationship with Chase. The Supreme Court affirmed, holding that the hearing justice’s grant of summary judgment in Chase’s favor was proper. View "Pineda v. Chase Bank USA, N.A." on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of felony assault following a jury-waived trial.On appeal, Defendant argued (1) there was sufficient evidence of self-defense to require a finding of not guilty, and (2) the trial justice overlooked material evidence in carrying out his fact-finding function. The Supreme Court disagreed, holding (1) the state successfully rebutted Defendant’s self-defense claim beyond a reasonable doubt; and (2) there was no error in Defendant’s trial. View "State v. Lussier" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Plaintiffs in this declaratory judgment action seeking a declaration that an amendment to a declaration creating a condominium complex adopted by Defendant was invalid.Defendant owned nine of the thirteen condominium units in the condominium complex and was therefore the majority owner. Plaintiffs owned the remaining four units. The original declaration expressly prohibited a restaurant use. Defendant, however, unilaterally adopted and recorded a “second amendment” to the declaration that expressly included “restaurant use” as a new permitted use relative to the units owned by Defendant. Plaintiffs brought this action arguing that, to be valid, the adoption of the second amendment required unanimous consent of all the owners pursuant to R.I. Gen. Laws 34-36.1-2.17(d). The hearing justice agreed and granted summary judgment for Plaintiffs. The Supreme Court agreed, holding that for the amendment to be valid, unanimous approval of all unit owners was required pursuant to section 34-36.1-2.17(d). View "Epic Enterprises LLC v. Bard Group, LLC" on Justia Law

The Supreme Court vacated the decision of the superior court granting summary judgment in favor of Plaintiffs on count one of Plaintiffs’ complaint sounding in adverse possession, holding that granting summary judgment in light of obvious disputed material facts was erroneous.Plaintiffs filed an amended complaint requesting that they be adjudged the rightful owners of certain property by virtue of adverse possession and seeking injunctive and declaratory relief. Defendants filed a counterclaim seeking to quiet title with respect to the disputed areas. A hearing justice granted Plaintiffs’ motion for summary judgment solely as to the adverse possession count. The Supreme Court vacated the judgment, holding that there were genuine issues of material fact as to the boundaries of the disputed areas that were not capable of resolution under Rule 56 of the Superior Court Rules of Civil Procedure. View "Coscina v. DiPetrillo" on Justia Law

At issue was whether Plaintiff was entitled to relief under Rule 60(b)(6) of the Superior Court Rules of Civil Procedure from an order directing him to remove a garage from his property.In 2014, the superior court ordered Plaintiff to remove a garage he built on his property that violated the setback requirements set forth in the Town of Tiverton’s zoning ordinance. Thereafter, the Town removed the garage from Plaintiff’s property and placed a lien on the property for $69,300 in fines imposed by a 2015 contempt order. In 2016, Plaintiff filed a motion to vacate the 2014 order. The trial judge denied the motion.The Supreme Court reversed, holding (1) because the superior court possessed subject matter jurisdiction to order Plaintiff to remove his garage, and because the granting of the 2014 order did not violate due process, the order was not void; but (2) the unique circumstances of this case and its procedural flaws presented a manifest injustice justifying relief from the operation of the order under Rule 60(b)(6). View "McLaughlin v. Zoning Board of Review of the Town of Tiverton" on Justia Law