Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court convicting Defendant for the second-degree murder of his girlfriend’s six-year-old son.On appeal, Defendant claimed that he was entitled to a new trial because the trial justice erred in instructing the jury and in admitting certain testimony at trial. The Supreme Court disagreed, holding (1) the trial justice did not err with respect to her instruction on second-degree felony murder; (2) the trial justice did not err with respect to her instruction on causation; and (3) the trial justice did not err in allowing the challenged testimony once Defendant opened the door to its relevancy. View "State v. Pati" on Justia Law

The Supreme Court affirmed the decree of the family court declaring that Mother neglected and abused her two children, Madlyn and Luke.Specifically, the Court held (1) there was sufficient evidence to support an inference that Mother had abused and neglected Luke; (2) the trial justice did not err in finding that Mother was Luke’s primary caregiver and that it was reasonable to infer that Mother either perpetrated physical abuse upon Luke or allowed the same to occur; (3) Mother’s argument that certain statements made by a physician were inadmissible hearsay was waived; and (4) the trial justice did not abuse his discretion in allowing Father to remain in the courtroom, notwithstanding Mother’s motion to sequester. View "In re Madlyn B." on Justia Law

In this appeal by the Rhode Island Troopers Association from a judgment granting declaratory and equitable relief in favor of the State, the Supreme Court affirmed the first six declarations and vacated the remaining two declarations in the superior court’s judgment.Here, the superior court (1) declared that the Governmental Tort Liability Act, R.I. Gen. Laws chapter 31 of title 9, vests the Attorney General with the nondelegable, nontransferable legal duty to determine whether the State should provide a defense and indemnification in a civil action brought against a state employee; and (2) permanently enjoined arbitration of issues related to the Attorney General’s decision to decline to provide a defense and indemnification for a state trooper in a federal civil rights action brought against him in his individual capacity. The Supreme Court held (1) the trial court properly enjoined the arbitration proceedings because the issues raised were not arbitrable within the collective bargaining process; (2) the superior court properly declared that the Attorney General possesses the nondelegable, nontransferable, sole legal duty to determine whether a state employee was acting within the scope of employment and is therefore entitled to a defense and indemnification; and (3) the remaining two declarations were superfluous to the issues in this case. View "State v. Rhode Island Troopers Ass’n" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of murder and discharging a firearm while committing a crime of violence, among other crimes.Specifically, the Court held (1) Defendant’s argument that the trial justice erred by allowing a Providence police detective to offer a lay opinion regarding the location of a particular cell phone at a certain point in time was waived because Defendant did not object at trial; and (2) the trial justice did not err by denying Defendant’s motion for a new trial based on the weight of the evidence. View "State v. Moten" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying postconviction relief for Appellant, who challenged the trial court’s acceptance of his nolo contendere plea on a second-degree murder charge.At sentencing, the hearing justice sentenced Appellant to the maximum sentence under the “capped” plea agreement - sixty years’ imprisonment, with twenty years suspended with probation following Appellant’s release. Appellant later filed a pro se application for postconviction relief arguing that he received ineffective assistance of counsel and that the hearing justice failed adequately to explain Appellant’s waiver of constitutional rights when he pled nolo contendere. The superior court denied relief. The Supreme Court affirmed, holding (1) the postconviction relief justice did not overlook or misconceive material evidence, nor did she clearly err in denying Appellant’s postconviction relief application; and (2) any issues related to Shatney v. State, 755 A.2d 130 (R.I. 2000), were cured in this case. View "Navarro v. State" on Justia Law

The Supreme Court affirmed the judgment of the superior court entering summary judgment in favor of Defendants, the City of Providence and various City officials, on Plaintiff’s complaint alleging, among other things, that Ira Lukens suffered serious injuries as a result of the City’s negligence in maintaining Roger Williams Park.On appeal, Plaintiff asserted that there remained genuine issues of material fact whether the City knew of the dangerous condition of a pothole on a park street and whether it “willfully and/or maliciously failed to warn against it,” which would strip the City of the protection against liability afforded under Rhode Islan d’s Recreational Use Statute (RUS). The Supreme Court held (1) immunity under the RUS clearly applied to the City; and (2) the exception provided in R.I. Gen. Stat. 32-6-5(a)(1) did not apply because there was no evidence that the City had actual knowledge of the pothole or had received complaints regarding the condition of the roadway. View "Cancel v. City of Providence" on Justia Law

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