Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the superior court in favor of Santander Bank, N.A. in this complaint challenging Santander’s foreclosure of Plaintiff’s property.In her complaint, Plaintiff alleged that Santander had failed to comply with the statutory notice requirements before it conducted the foreclosure sale. A justice of the superior court granted Santander’s motion for summary judgment. The Supreme Court affirmed, holding that summary judgment was appropriate because there was no genuine issue of material fact with respect to whether Santander complied with the notice requirements of R.I. Gen. Laws 34-27-4(a) and 34-27-4)b. View "Adams v. Santander Bank, N.A." on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of robbery in the first degree and conspiracy after a jury trial.On appeal, Defendant requested a new trial on the grounds that the trial justice erred in admitting into evidence identification testimony and a photograph identification. The Supreme Court affirmed the judgment of the superior court, holding (1) the trial justice did not abuse his discretion in admitting the contested identification testimony because the testimony was not impermissible hearsay; and (2) the trial justice did not abuse his discretion in admitting a single photograph of Defendant into evidence because the use of a single photograph was not unduly suggestive and did not implicate Defendant’s right to due process. View "State v. Alves" on Justia Law

The Supreme Court quashed the judgment of the superior court that reversed a decision by the Rhode Island Department of Health (DOH) to grant Petitioner’s application for a Health Care Certificate of Need (CON) on the basis that Petitioner’s application did not demonstrate a public need.The Supreme Court disagreed, holding (1) the DOH correctly applied its rules and regulations when it determined that the public need set forth in Petitioner’s application was appropriate; and (2) the DOH relied upon competent evidence for future public need in support of its decision to grant Petitioner’s CON application. View "Endoscopy Associates, Inc. v. Rhode Island Department of Health" on Justia Law

The Supreme Court quashed the judgment of the superior court that reversed a decision by the Rhode Island Department of Health (DOH) to grant Petitioner’s application for a Health Care Certificate of Need (CON) on the basis that Petitioner’s application did not demonstrate a public need.The Supreme Court disagreed, holding (1) the DOH correctly applied its rules and regulations when it determined that the public need set forth in Petitioner’s application was appropriate; and (2) the DOH relied upon competent evidence for future public need in support of its decision to grant Petitioner’s CON application. View "Endoscopy Associates, Inc. v. Rhode Island Department of Health" on Justia Law

The Supreme Court vacated the judgment of the superior court granting summary judgment for Defendants on Plaintiff’s negligence claim.Plaintiff, a former college hockey player, filed this negligence suit alleging that he inhaled noxious fumes while playing in a game at an arena owned by Defendant DRF Arena, LLC and operated by Defendant Rhode Island Sports Center, Inc. The superior court granted summary judgment in favor of Defendants. The Supreme Court vacated the superior court’s judgment and remanded the case for trial, holding that Defendants’ alleged negligence was a question that should have been left for the jury, and therefore, the superior court erred by disposing of the case by summary judgment. View "DeLong v. Rhode Island Sports Center, Inc." on Justia Law

The Supreme Court vacated the judgment of the superior court and remanded this case to the superior court with directions to hear and decide Plaintiff’s motion to amend his complaint upon the merits, holding that the trial justice erred in failing to address Plaintiff’s motion to file a second amended complaint.Plaintiff, an inmate, filed an amended civil complaint alleging negligence on the part of State defendants. Before trial, the trial justice sua sponte raised the issue of the civil death statute in light of Plaintiff’s sentences of life imprisonment. Defendants then filed a motion to dismiss the case under R.I. Gen. Laws 13-6-1, arguing that Plaintiff was deemed civilly dead, and therefore, his civil rights were effectively terminated. Plaintiff then filed a motion for leave to file a second amended complaint seeking to add a claim for violations of Plaintiff’s constitutional rights under color of law. The trial justice granted Defendants’ motion to dismiss based on the civil death statute and did not address Plaintiff’s motion for leave to file a second amended complaint. The Supreme Court held that the trial justice accurately dismissed the case but should have addressed Plaintiff’s second amended complaint before granting Defendants’ motion to dismiss. View "Gallop v. Adult Correctional Institutions" on Justia Law

At issue was whether Plaintiffs, a group of taxpayers in the Town of Portsmouth, were required to base their tax appeals on the fair market value of their properties as of December 31 in the year of the last update or revaluation.The value of Plaintiffs’ properties decreased in 2008 and 2009. The trial justice found that Plaintiffs could challenge the Portsmouth tax assessor’s (Defendant) tax assessments for tax years 2009 and 2010 using the fair market values of their properties as of December 31, 2008 and December 31, 2009, respectively, thus concluding that Plaintiffs were not confined to December 31, 2007 valuations. The Supreme Court affirmed, holding that Plaintiffs were authorized under chapter 5 of title 44 of the Rhode Island General Laws to challenge Defendant’s assessments for tax years 2009 and 2010 by employing the fair market values of their properties as of December 31, 2008 and December 31, 2009, respectively. View "Balmuth v. Dolce" 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 and one count of second-degree child molestation sexual assault, holding that the trial justice did not err in granting the State’s motion in limine and in admitting the testimony of three witnesses about alleged incidents of Defendant’s prior sexual misconduct under R.I. R. Evid. 404(b).On appeal, Defendant argued that the alleged prior sexual misconduct was too remote and dissimilar to the charged acts to be admissible. The Supreme Court disagreed, holding (1) the challenged testimony satisfied the “nonremote” and “similar” requirements of Rule 404(b) jurisprudence; (2) the evidence was relevant to the crime charged and reasonably necessary; (3) the risk of prejudice did not outweigh the probative value of the allegations of prior sexual misconduct; and (4) there was no error in the trial justice’s analysis under Rule 29(b) of the Superior Court Rules of Criminal Procedure in denying Defendant’s motion to dismiss. View "State v. Perry" on Justia Law

Contrary to the conclusions of the magistrate and the hearing justice, Defendant did not have a lifetime duty to register, but rather, his duty to register expired ten years from the expiration of his sentence for the offense of second-degree child molestation sexual assault, in accordance with R. I. Gen. Stat. 11-37.1-18 and 11.37.1-4(a). Further, Defendant’s three prior failure-to-notify convictions did not run afoul of the ex post facto clause.Defendant filed a motion to dismiss a 2012 charge for failing to notify law enforcement of a change in residence. The magistrate denied the motion, determining that Defendant had a lifetime duty to register. Defendant then filed an application for postconviction relief from his three prior failure-to-notify convictions in 2007, 2009, and 2010. A justice of the superior court denied relief, concluding that Defendant had a lifetime duty to register and that his three failure-no-notify convictions did not violate the ex post facto clause. The Supreme Court (1) affirmed the part of the magistrate’s decision denying the motion to dismiss but reversed the magistrate’s ruling that Defendant had a lifetime duty to register as a sex offender; and (2) affirmed the judgment denying postconviction relief but reversed the hearing justice’s ruling that Defendant’s obligation to register was for the remainder of his life. View "State v. Gibson" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of West Davisville Realty Co., LLC (West Davisville) holding David Paolo liable on a personal guaranty of a termination of lease agreement between West Davisville and Alpha Nutrition, Inc. (Alpha).West Davisville filed a complaint against Alpha and Paolo alleging breach of contract and unjust enrichment. The hearing justice granted West Davisville’s motion for summary judgment. The Supreme Court affirmed, holding (1) any attempt by Paolo to point to purported evidence that West Davisville fraudulently induced Paolo to personally guarantee the agreements was not relevant in this appeal; and (2) the personal guaranty was valid because the underlying termination agreement was supported by consideration. View "West Davisville Realty Co. v. Alpha Nutrition, Inc." on Justia Law