Justia Rhode Island Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the superior court convicting Defendant of one count of first-degree child molestation sexual assault and one count of the sale or distribution of photographs of a minor suggesting that the minor engaged in, or is about to engage in, a sexual act. On appeal, Defendant argued that the trial court violated his Sixth Amendment right to cross-examine the complaining witness regarding her allegations against her biological father. The Supreme Court disagreed, holding that the trial justice did not abuse his discretion in precluding the admission of this evidence. View "State v. Danis" on Justia Law

The Supreme Court vacated the decision of the superior court granting Defendant’s motion to suppress statements he made to a Massachusetts Department of Children and Families investigator on grounds that the investigator’s failure to advise Defendant of his right to counsel rendered the statements involuntary.Defendant was indicted by a grand jury on four counts of child molestation. The Supreme Court vacated the decision of the hearing justice granting Defendant’s motion to suppress, holding that, under the circumstances of this case, Defendant’s statements were voluntary, and the motion to suppress should have been denied. View "State v. Gouin" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendant, the City of Providence, on Plaintiff’s amended complaint alleging that she fell and sustained injuries due to the City’s negligence in maintaining its sidewalk, holding that Plaintiff failed to provide notice of the location of her injury in a “reasonably sufficient manner.”In dismissing the complaint, the superior court concluded that Plaintiff’s notice of claim failed to describe with sufficient specificity of location where the incident giving rise to the claim occurred was defective as a matter of law. The Supreme Court agreed, holding that because Plaintiff’s notice was geographically inaccurate, it was inadequate, and Plaintiff’s attempt to cure the defective notice was invalid because it was filed outside the sixty-day limitations period for filing a notice of claim under R.I. Gen. Laws 45-15-9. View "Ahearn v. City of Providence" on Justia Law

In this protracted litigation between Carol and A.L. Ballard and SVF Foundation and the Foundation’s predecessor owner regarding certain property, the Supreme Court affirmed summary judgments and an order of dismissal entered by the superior court on the eve of trial. The Court held that, contrary to the Ballards’ contentions on appeal, the superior court properly entered judgments on claims concerning the property sewer system and a driveway easement, properly dismissed an accounting claim based on an in-court conference, and did not err in denying the Ballards’ motion for sanctions pursuant to Rule 11 of the Superior Court Rules of Civil Procedure against the attorney for the Foundation. View "Ballard v. SVF Foundation" on Justia Law

The Supreme Court affirmed the judgment of the family court terminating Mother’s parental rights with respect to her three children. After a trial, the trial justice concluded that, by clear and convincing evidence, the Department of Children, Youth and Families (DCYF) had proven that the three children had been in the legal care and custody for at least twelve months, that DCYF had made reasonable efforts to offer Mother services to correct the situation, and that, notwithstanding DCYF’s efforts, Mother had failed to address her parenting and substance abuse issues. Further, the trial justice found that terminating Mother’s parental rights was in the best interests of the children. The Supreme Court affirmed, holding that the trial justice did not overlook or misconceive material evidence in finding that Mother was unfit to parent her three children, and therefore, the trial justice did not err when she terminated Mother’s parental rights as to the three children. View "In re James H." on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Petitioner’s application for postconviction relief, in which Petitioner claimed that he received ineffective assistance of trial counsel. The Court held (1) Petitioner’s trial counsel was not ineffective for failing to utilize an expert witness on false confessions; (2) the trial justice did not clearly err in refusing to approve funding for the hiring of an expert witness on false confessions in this postconviction relief action; and (3) trial counsel was not ineffective for failing to file a motion to recuse the justice during the trial, and the trial justice did not err in not recusing himself from hearing the instant application for postconviction relief. View "Barros v. State" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Petitioner’s application for postconviction relief, in which Petitioner claimed that he received ineffective assistance of trial counsel. The Court held (1) Petitioner’s trial counsel was not ineffective for failing to utilize an expert witness on false confessions; (2) the trial justice did not clearly err in refusing to approve funding for the hiring of an expert witness on false confessions in this postconviction relief action; and (3) trial counsel was not ineffective for failing to file a motion to recuse the justice during the trial, and the trial justice did not err in not recusing himself from hearing the instant application for postconviction relief. View "Barros v. State" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting the motions for summary judgment filed by Defendants - a Union and the Treasurer for the City of Providence - holding that the Court need not pass on the merits of the superior court’s ruling because, under the raise-or-waive rule, Plaintiff forfeited his right to appellate review.On appeal, Plaintiff argued that the hearing justice erred in granting Defendants’ motions for summary judgment because the City could not terminate him for off-duty conduct and because the Union did not comply with its duty to fairly represent him. The Supreme Court held that Plaintiff was precluded from pursuing his right to appellate review because he failed to comply with the dictates of Rule 16(a) of the Supreme Court Rules of Appellate Procedure in his appellate brief in this case. View "Terzian v. Lombardi" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting the motions for summary judgment filed by Defendants - a Union and the Treasurer for the City of Providence - holding that the Court need not pass on the merits of the superior court’s ruling because, under the raise-or-waive rule, Plaintiff forfeited his right to appellate review.On appeal, Plaintiff argued that the hearing justice erred in granting Defendants’ motions for summary judgment because the City could not terminate him for off-duty conduct and because the Union did not comply with its duty to fairly represent him. The Supreme Court held that Plaintiff was precluded from pursuing his right to appellate review because he failed to comply with the dictates of Rule 16(a) of the Supreme Court Rules of Appellate Procedure in his appellate brief in this case. View "Terzian v. Lombardi" on Justia Law