Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the superior court granted summary judgment in favor of Defendants on Plaintiff’s complaint alleging intentional infliction of emotional distress, negligent infliction of emotional distress, loss of consortium, and invasion of privacy.Plaintiff’s claims stemmed from an incident in which one of the defendants allegedly berated Plaintiff, a Providence Fire Department employee, for allowing one of his dispatchers to be sprawled in his chair while on duty. Plaintiff was later transferred and demoted. Plaintiff filed two grievances against the City, alleging breach of the applicable collective bargaining agreement. The grievances were settled at arbitration for a monetary payment. After Plaintiff retired, he filed this complaint against the City and some of its officers. The hearing justice granted summary judgment in favor of Defendants on all counts of Plaintiff’s complaint. The Supreme Court affirmed, holding that Plaintiff failed to allege any conduct by the City that was extreme or outrageous. View "Gross v. Pare" on Justia Law

The Supreme Court affirmed the judgment of the superior court dismissing Plaintiffs’ second amended complaint with prejudice, holding that the hearing justice did not err in dismissing the complaint.In their second amended complaint, Plaintiffs challenged the constitutionality of the statutory system for appointing magistrates to the Rhode Island Traffic Tribunal. Specifically, Plaintiffs claimed that they were due a refund of fines and costs that had previously been assessed by the Traffic Tribunal because Defendants’ conduct was unconstitutional. Plaintiffs further argued that Defendants had been unjustly enriched by levying those fines. Defendants moved to dismiss Plaintiffs’ complaint with prejudice pursuant to Rules 12(b)(1) and 12(b)(6) of the Superior Court Rules of Civil Procedure. The justice granted the motion. The Supreme Court affirmed, holding that Plaintiffs’ complaint failed to state a viable claim for relief as to Plaintiffs’ constitutional claim and that the complaint failed to allege the facts necessary to support the unjust enrichment claim. View "McKenna v. Guglietta" on Justia Law

The arbitrator in this case did not manifestly disregard the law or the provisions of the employment agreement at issue when he awarded Defendant extended severance payments based on his finding that Defendant had been the subject of a “de facto termination.”Defendant, the former vice president and chief financial officer of CharterCAREHealth Partners (Plaintiff), invoked the “de facto termination” provision of the parties' employment agreement and requested extended severance, contending that he had suffered a material reduction in his duties and authorities as a result of change in “effective control.” Defendant’s request was denied based on the assessment that he had suffered no material reduction in duties. Defendant filed a demand for arbitration seeking to be awarded extended severance benefits pursuant to the de facto termination provision of the employment agreement. The arbitrator determined that Defendant was entitled to the eighteen-month severance proscribed in the agreement’s de facto termination clause. Plaintiff filed a petition to vacate the arbitration award. The superior court denied the motion to vacate and granted Defendant’ motion to confirm the arbitration award. The Supreme Court affirmed, holding that there was nothing in the record to support Plaintiff’s contention that the arbitrator exceeded his powers or manifestly disregarded the law or the contract. View "Prospect CharterCARE, LLC v. Conklin" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of murder, conspiracy to commit murder, and discharging a weapon while committing a crime of violence.On appeal, Defendant argued that the trial justice abused his discretion in denying his motions to pass and in overruling his objections to photographic evidence and erred in denying his motion for a new trial. The Supreme Court disagreed, holding (1) the trial justice did not err in denying Defendant’s motions to pass and motions for mistrial; (2) the trial justice did not abuse his discretion in admitting the photograph at issue; and (3) Defendant’s disagreement with the trial justice’s credibility determination was an insufficient basis for reversal. View "State v. Alexis" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of murder, conspiracy to commit murder, and discharging a weapon while committing a crime of violence.On appeal, Defendant argued that the trial justice abused his discretion in denying his motions to pass and in overruling his objections to photographic evidence and erred in denying his motion for a new trial. The Supreme Court disagreed, holding (1) the trial justice did not err in denying Defendant’s motions to pass and motions for mistrial; (2) the trial justice did not abuse his discretion in admitting the photograph at issue; and (3) Defendant’s disagreement with the trial justice’s credibility determination was an insufficient basis for reversal. View "State v. Alexis" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of two counts of first-degree sexual assault.On appeal, Defendant argued, among other things, that the trial justice should have granted his motion for a mistrial due to what he termed the prosecutor’s comment on his failure to testify. The Supreme Court held (1) the trial justice correctly found that the prosecutor’s statement, taken in context, did not improperly comment on Defendant’s failure to testify and thus did not violate Defendant’s Fifth Amendment rights; (2) the trial justice did not commit reversible error in admitting Defendant’s “mug shot” into evidence; and (3) the trial justice did not err by denying Defendant’s motion for new trial. View "State v. Marizan" on Justia Law

The Supreme Court vacated the judgment of the family court finding that Defendant and Plaintiff were married at common law, holding that the trial justice’s factual findings did not represent “a firm belief or conviction” that the parties seriously intended to enter into a mutual husband and wife relationship.Plaintiff filed for a divorce from Defendant. The family court found clear and convincing evidence that the parties were married at common law since 1995, concluding that Defendant’s testimony was largely incredible and Plaintiff’s testimony was mostly credible. The Supreme Court reversed, holding that the trial justice misconceived the evidence in finding that Defendant and Plaintiff had a present and mutual intent to be married at common law. View "Luis v. Gaugler" on Justia Law

The Supreme Court vacated in part and affirmed in part the Supreme Court’s grant of summary judgment in favor of Defendants - the Town of Scituate and others - on Plaintiff’s claims alleging breach of a memorandum of understanding (MOU).Specifically, Plaintiff alleged promissory estoppel and breach of contract, breach of confidentiality, tortious interference with a contract, and fraudulent misrepresentation. The trial justice granted summary judgment for Defendants, finding, among other things, that the MOU was not a binding agreement. The Supreme Court vacated the portion of the judgment granting summary judgment on Plaintiff’s breach of contract claim and otherwise affirmed, holding that the facts presented established that a contract was formed. View "Coccoli v. Town of Scituate Town Council" on Justia Law

The Supreme Court affirmed the order of the superior court granting the motions to dismiss filed by Defendants, Bank of America, N.A. (BOA) and EverBank Mortgage (EverBank), on Plaintiff’s complaint seeking monetary damages for breach of contract and breach of the implied covenant of good faith and fair dealing, as well as a preliminary injunction to stop a foreclosure.Plaintiff executed a mortgage on his property in favor of Mortgage Electronic Registration Systems, Inc. (MERS). The mortgage was later assigned to BOA. After the BOA informed Plaintiff that his mortgage was in foreclosure he filed a complaint alleging, inter alia, that the assignment of the mortgage was void and that Defendants had no standing to foreclose on his property. A federal court granted Defendants’ motion to dismiss. Thereafter, Plaintiff brought this complaint. Defendants filed motions to dismiss. The superior court found that res judicata warranted the granting of Defendants’ motions to dismiss. The Supreme Court affirmed, holding that res judicata applied. View "Goodrow v. Bank of America, N.A." on Justia Law

The Supreme Court dismissed this appeal brought by the Rhode Island Department of Environmental Management (DEM) and the State, holding that an appeal from a final judgment of the superior court brought under R.I. Gen. Laws 42-17-.1-2(21) must proceed by way of a petition for a writ of certiorari.The DEM commenced this action against Defendants seeking injunctive relief to enforce a compliance order that Defendants remediate certain property. The DEM also sought enforcement of is administrative penalty, arguing that its authority to do so arose from section 42-17-.1-2(21). DEM subsequently released Defendants from the remediation requirement but continued to seek enforcement of the administrative penalty. The trial justice concluded that DEM could not enforce an administrative penalty in the context of an action for injunctive relief. The DEM filed a notice of appeal. The Supreme Court dismissed the appeal, holding that the appeal was not properly before the Court. View "Coit v. Coccoli" on Justia Law