Justia Rhode Island Supreme Court Opinion Summaries

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

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