Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court vacated the judgment of the superior court denying Petitioner’s application for postconviction relief, in which he alleged that his constitutional rights were violated when his parole was revoked and he was denied the possibility of parole in the future.After Petitioner was granted parole, he was arrested in Pennsylvania and convicted of one count of aggravated assault. In 1994, while Petitioner was serving his sentence in Pennsylvania, the Rhode Island Parole Board voted to revoke Petitioner’s parole and indicated that he would no longer be eligible for parole. Upon completion of his prison term in Pennsylvania, Petitioner, in 2014, appeared again before the Parole Board. The Parole Board affirmed the revocation of Petitioner’s parole and stated that Petitioner would forever remain ineligible for parole consideration. The Supreme Court held that it was error for the Parole Board to have denied Petitioner counsel at the 1994 hearing and the 2014 hearing and remanded the case with instructions that the superior court remand this case to the Parole Board to conduct a new parole revocation hearing. View "Jefferson v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the superior court granting a motion to dismiss brought by Defendants in this case alleging that Defendants, including ESS Group, Inc., violated the Rhode Island Whistleblowers’ Protection Act, R.I. Gen. Laws chapter 50 of title 28 (WPA), and the Rhode Island Business Corporation Act (BCA), R.I. Gen. Laws chapter 7-1.2.The hearing justice determined that Plaintiff’s complaint failed to state a claim upon which relief could be granted and dismissed the action. Specifically, the hearing justice found (1) Defendants’ conduct did not violate the BCA because Rhode Island has no authority to regulate the internal affairs of a foreign corporation, such as ESS, and the provisions that Defendants allegedly violated did not apply because the provisions use the term “corporation,” not “foreign corporation”; and (2) Plaintiff failed to assert a WPA claim premised on Defendants’ alleged BCA violations because ESS was not subject to the BCA. The Supreme Court held (1) Plaintiff was not entitled to relief under the BCA count; but (2) Plaintiff’s complaint sufficiently pled a WPA claim. View "Rein v. ESS Group, Inc." on Justia Law

The Supreme Court vacated the judgment of the superior court granting a motion brought by Defendant, the State Public Defender’s Office, for judgment on the pleadings regarding Plaintiff’s employment discrimination claims.Plaintiff in this case filed two complaints. In Nugent I, Plaintiff appealed an arbitration decision concluding that the Public Defender’s Office acted wth just cause when it terminated Plaintiff’s employment. Judgment entered in favor of Defendant on the basis that Plaintiff lacked standing to challenge the arbitration decision in court. In Nugent II, Plaintiff alleged unlawful employment discrimination. Defendant moved for judgment on the pleadings, arguing that res judicata barred Plaintiff’s discrimination claims. The hearing justice granted the motion, and final judgment entered in favor of Defendant on all claims. The Supreme Court vacated the judgment in Nugent II, holding that Nugent I was not a final judgment for purposes of res judicata because the consideration of Nugent’s standing did not reach the merits of Nugent I, and therefore, Plaintiff was not barred from seeking redress for her discrimination claims raised in Nugent II. View "Nugent v. State" on Justia Law

The Supreme Court affirmed the judgment of the superior court quashing an execution previously issued by the Rhode Island Superior Court on a State of Utah District Court judgment and dismissing George Hawes’s petition to enforce the Utah judgment on the grounds that Utah did not have personal jurisdiction over Daniel Reilly.InnerLight Holdings, Inc. filed a complaint in state court in Utah against several defendants, including Reilly and Hawes. Hawes filed a cross-claim against Reilly and others. Reilly moved to dismiss the complaint on the ground that Utah did not have personal jurisdiction over him. The Utah District Court denied the motion to dismiss. Thereafter, a default judgment on Hawes’s cross-claim was entered against Reilly. Hawes filed a petition to enforce a foreign judgment in the Rhode Island Superior Court. The hearing justice denied the petition, concluding that Utah did not have personal jurisdiction over Reilly. The Supreme Court affirmed, holding (1) the Utah order denying the motion to dismiss was not entitled to full faith and credit; (2) Utah did not have personal jurisdiction over Reilly; and (3) Reilly did not forfeit his defense of lack of personal jurisdiction. View "Hawes v. Reilly" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of the Dunn’s Corners Fire District on its complaint seeking a declaration that it was not obligated to provide fire protection services to certain property located in the Village of Bradford in the town of Westerly, Rhode Island.Dunn’s Corners was a party to a contract that required Westerly Ambulance Corps, also a defendant in this case, to dispatch Dunn’s Corners to sites and locations situated within the Bradford Fire District. The hearing justice granted Dunn’s Corners’ motion for summary judgment, finding that the subject property lay outside of the Bradford Fire District. The Supreme Court affirmed, holding (1) Appellant’s argument that a declaratory judgment should not have issued because the Bradford Fire District was not a party to the action lacked merit; and (2) because Appellant conceded at oral argument that the subject property was not currently situated within any fire district, Appellant’s second argument that there remained a genuine issue of material fact as to whether the property was located within the Bradford Fire District was without merit. View "Dunn’s Corners Fire District v. Westerly Ambulance Corps" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the superior court granting summary judgment for Defendant, Price Rite, on count one of Plaintiff’s complaint and also granting Defendant’s motion to dismiss the remaining four counts.Plaintiff slipped and fell on liquid in an aisle of a store owned by Defendant. Plaintiff’s amended complaint alleged negligence, breach of contract, mode of operation, failure to warn, and breach of the implied warranties of merchantability, fitness for use, and fitness for a particular purpose. The court granted summary judgment on the negligence count and dismissed the remaining counts. The Supreme Court vacated the judgment of the superior court granting summary judgment on Plaintiff’s negligence claim and affirmed the dismissal of the remaining counts, holding (1) Plaintiff satisfied her burden of producing competent evidence that proved the existence of a disputed issue of material fact with respect to Defendant’s safety procedures or lack thereof, (2) the trial judge impermissibly weighed the evidence in his decision granting summary judgment, and (3) there is no requirement at the summary judgment stage for a plaintiff to produce direct evidence of how long a spill has existed on a floor. View "Dent v. PRRC, Inc." on Justia Law

The Supreme Court affirmed the judgment of the superior court vacating an arbitration award that reinstated Michael Crenshaw to his position as a campus police officer for the Community College of Rhode Island.Crenshaw was allowed to continue in his employment for almost a year without completing the statutorily required police training academy or receiving a waiver from having to do so. When, eventually, Crenshaw’s application for a waiver was not approved, the college terminated his employment. CCRI Educational Support Professional Association/NEARI (the union) brought this grievance. The college denied the grievance, and arbitration ensued. The arbitrator ordered that Crenshaw be reinstated to his position and compensated for lost time. The superior court granted the college’s petition to vacate the arbitration award on the grounds that it was irrational and manifestly disregarded a statutory requirement. The Supreme Court affirmed, holding that the arbitrator exceeded his powers by arbitrating a dispute that was nonarbitrable from the start because Crenshaw’s conditional offer of employment was conditioned on his satisfaction of the statutorily mandated academy requirement. View "Community College of Rhode Island v. CCRI Educational Support Professional Ass’n" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of two counts of first-degree child molestation sexual assault, for which Defendant received two concurrent forty-year sentences.On appeal, the Court held that the trial justice did not err by (1) refusing to the testimony of Natalie Kissoon, M.D. in its entirety for lack of foundation; (2) refusing to grant Defendant’s motion to pass the case after Dr. Kissoon testified that the victim’s disclosures were consistent with sexual abuse; and (3) denying Defendant’s motion for a new trial based upon newly discovered evidence. View "State v. Rathbun" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Defendant’s application for postconviction relief in which Defendant argued that he had received ineffective assistance of counsel because his lawyer was not licensed to practice law in Rhode Island.Defendant pled nolo contendere to two criminal offenses and admitted to violating his probationary sentence. In his postconviction relief application, Defendant argued that he received ineffective assistance of counsel because his defense counsel, who was not licensed to practice law in Rhode Island, was engaging in unlawful conduct. Defendant further argued that his defense counsel’s associate, who was licensed in Rhode Island and who appeared in court with Defendant, was a “straw man” and thus complicit in the scheme to practice law without a license. The superior court denied the application. The Supreme Court affirmed, holding (1) the trial justice properly found that defense counsel’s associate, not defense counsel, represented Defendant with respect to his pleas; and (2) Defendant’s argument that defense counsel and the associate had a conflict of interest in representing Defendant lacked merit. View "Millette v. State" on Justia Law

The Supreme Court vacated the judgment of the superior court in favor of the Town of Cumberland granting its motion to vacate an arbitration award in favor of Defendants, the Cumberland Town Employees Union and Norman Tremblay (collectively, the Union).The Town terminated Tremblay’s employment more than one year after Tremblay was injured at work. The Union filed an arbitration demand on Tremblay’s behalf pursuant to the collective bargaining agreement (the CBA) between the Town and the Union. The arbitrator concluded that Tremblay’s grievance was arbitrable and directed the Town to reinstate Tremblay. A superior court hearing justice vacated the award, explaining that the Workers’ Compensation Court had exclusive jurisdiction over reinstatement disputes. The Supreme Court disagreed, holding (1) the Union did not seek Tremblay’s reinstatement under the Workers’ Compensation Act (WCA) but, rather, sought reinstatement based on the rights that the Union asserted the CBA afforded Tremblay beyond those delineated in the WCA; and (2) the Union’s contention that the CBA granted Tremblay greater rights than the WCA was one that the arbitrator could properly decide. View "Town of Cumberland v. Cumberland Town Employees Union" on Justia Law