Justia Rhode Island Supreme Court Opinion Summaries

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

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