Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed in part and vacated in part the judgment of the superior court denying the motion filed by the Rhode Island Council on Postsecondary Education and the University of Rhode Island (collectively URI) seeking to vacate an arbitration award and confirming the award.After the American Association of University Professors, Part-Time Faculty United (the union) filed a grievance on behalf of a part-time faculty member at URI based on the rescission of the faculty member’s “special programs contract” the union filed a demand for arbitration. The arbitrator determined that URI’s rescission of the faculty member’s contract violated the collective bargaining agreement and issued an award. The superior court denied URI’s motion to vacate the arbitration award and entered final judgment confirming the award. On appeal, the Supreme Court held (1) the grievance was arbitrable; (2) the rescission of the faculty member’s special programs contract was in violation of the CBA and required URI to pay the faculty member a $6,500 salary; but (3) the arbitrator exceeded his authority in ordering URI to cease and desist from unilaterally imposing a two course per semester limit on bargaining unit employees. View "Rhode Island Council on Postsecondary Education v. American Association of University Professors, Part-Time Faculty United" on Justia Law

In this employment dispute, the Supreme Court vacated the judgment of the superior court insofar as it granted the North Kingstown School Committee’s (“school committee”) motion to quash the subpoenas of two attorneys for the school committee, and affirmed the judgment in all other respects.After the school committee voted to terminate Teacher’s employment, Teacher appealed to the commissioner of elementary and secondary education within the Rhode Island Department of Elementary and Secondary Education (RIDE). At Teacher’s request, the RIDE hearing officer issued three subpoenas addressed to two attorneys for the school committee and a subpoena duces tecum to the North Kingstown School Department. In superior court, the school committee filed a petition to quash the three subpoenas issued by the RIDE hearing officer. The hearing justice granted in part and denied in part the motion. The Supreme Court vacated in part and affirmed in part the superior court’s judgment, holding that the hearing justice applied the attorney-client privilege to the attorneys’ anticipated testimony in an overly broad manner. The court remanded the case for further proceedings. View "North Kingstown School Committee v. Wagner" on Justia Law

The Supreme Court affirmed the decision of the superior court denying Plaintiff’s motion for a new trial following a jury verdict in favor of Defendants in this negligence case arising out of an automobile accident.In his motion for a new trial, Plaintiff argued that the jury failed to apply the facts to the law in the case at hand. The trial justice denied the motion, determining that reasonable minds could differ on the outcome of the case. The Supreme Court affirmed, holding that the trial justice properly conducted the analysis for a motion for a new trial and did not overlook or misconceive material evidence. View "Zarembka v. Whelan" on Justia Law

The Supreme Court affirmed the order of the superior court dismissing Plaintiff’s complaint for declaratory relief asserting that he had a right to access to records in the possession of the Rhode Island Department of Elementary and Secondary Education (RIDE) pursuant to the Access to Public Records Act (APRA). The motion justice found that the requested documents were not public records subject to disclosure under APRA. The Supreme Court agreed, holding that the records requested by Plaintiff were not public records for the purposes of APRA, and therefore, the motion justice properly disposed of Plaintiff’s complaint on RIDE’s motion to dismiss. View "Pontarelli v. R.I. Department of Elementary & Secondary Education" on Justia Law

Subsection 4(a) of Rhode Island’s Right to Farm Act, Rhode Island General Laws chapter 23 of title 2, does not permit Landowner to host commercial events, such as weddings for a fee, on his farmland in the Town of Exeter, Rhode Island.Landowner attempted to obtain a zoning certificate from the Town that would allow him to host a commercial fundraising event on his farmland. When the Town denied the request, Landowner filed suit, seeking a number of declarations. At issue was whether a 2014 amendment to R.I. Gen. Laws 2-23-4(a) rendered a previous permanent injunction enjoining Landowner from using his property for commercial events a nullity. The trial justice denied Landowner’s request for declaratory relief, concluding that the 2014 amendment did not supersede the 2011 injunction. The Supreme Court affirmed, holding that, based on the unambiguous language of section 2-23-4(a), Landowner remained bound by the injunction. View "Gerald P. Zarrella Trust v. Town of Exeter" on Justia Law

The Supreme Court quashed the decision of Respondent, the Chief of Police for the City of East Providence, denying Petitioner’s application for a permit or license to carry a concealed weapon and directed Respondent to issue a new decision setting forth findings of fact and conclusions of law in conformity with the Supreme Court’s holding in Gadomski v. Tavares, 113 A.3d 387 (R.I. 2015). Petitioner filed a petition for the issuance of a writ of certiorari, arguing that the nature of Respondent’s decision letter lacked the findings of fact and conclusions of law required pursuant to Gadomski. The Supreme Court agreed, holding that Respondent’s decision letter fell short of the court’s clear directive in Gadomski. View "Paiva v. Parella" on Justia Law

Collateral estoppel is not applicable to issues determined in the Rhode Island Traffic Tribunal when the issues are “only a small part of a larger, ongoing criminal investigation.”Defendant in this case was cited in the Rhode Island Traffic Tribunal with the civil violation of reasonable and prudent speeds. Defendant was also charged criminally in Superior Court with driving under the influence, serious bodily injury resulting and reckless driving. Defendant sought to dismiss his criminal charges, arguing that the Traffic Tribunal magistrate determined that he was not operating the vehicle, and therefore, the issue could not be relitigated based on collateral estoppel. The Superior Court magistrate granted the motion to dismiss. A Superior Court justice reversed the dismissal. The Supreme Court affirmed, holding that in matters that are only a small part of a larger, ongoing criminal investigation, the Traffic Tribunal’s process is insufficient to estop a later criminal proceeding. View "State v. Minior" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of two counts of first-degree child molestation and one count of second-degree child molestation. The court held (1) the trial justice did not abuse his discretion by failing to exclude certain testimony as a result of the State’s violation of Rule 16 of the Superior Court Rules of Criminal Procedure; (2) the trial judge did not err by admitting the testimony at issue pursuant to Rule 404(b) of the Rhode Island Rules of Evidence; (3) even if the testimony was admissible under Rule 404(b), the trial judge did not err in admitting the testimony under Rule 403 of the Rhode Island Rules of Evidence; (4) the trial judge did not overlook or misconceive material evidence in analyzing Defendant’s motion for new trial; and (5) the trial justice did not err in denying Defendant’s motion for judgment of acquittal. View "State v. Rainey" on Justia Law

The Supreme Court affirmed the decision of the superior court adjudging Defendant to have violated the terms and conditions of his probation and executing eighteen years of a twenty-year suspended sentence. On appeal, Defendant argued that the hearing justice “went far beyond the scope of the probation violated hearing in deciding that [Defendant] had committed first degree sexual assault by a fair preponderance of the evidence.” The Supreme Court disagreed, holding that the hearing justice did not err in finding that Defendant had violated the terms and conditions of his probation. View "State v. Simpson" on Justia Law

At issue was a decision of the Retirement Board of the Employees’ Retirement System of the City of Providence (City) to reduce the pension benefits of Frank Corrente after he was convicted of six felony counts in a federal district court. Specifically, the Board revoked a portion of Corrente’s pension benefits and ordered him to return a portion of the benefits that he had received. This appeal concerned three appeals - one by Corrente, another by intervenors the City Mayor and the City, and the third by the Board. The Supreme Court affirmed the judgment of the superior court, holding (1) the trial justice did not err in finding that the intervenors satisfied the requirements to intervene under Rule 24(a) of the Superior Court Rules of Civil Procedure; (2) the trial justice appropriately applied the standard of review set forth in the Administrative Procedures Act; (3) the Board’s decision to reduce, rather than revoke, Corrente’s pension benefits was not arbitrary, capricious, or affected by other errors or law; and (4) the trial justice did not err in confirming the retirement board’s decision to deny Corrente’s request for a tax credit on pension benefits that he had received but was required to return to the Board. View "Retirement Board of the Employees’ Retirement System of City of Providence v. Corrente" on Justia Law