Justia Rhode Island Supreme Court Opinion Summaries

A passenger in a moving vehicle who forcibly seizes the steering wheel has exercised sufficient control of the vehicle to be deemed a “driver” or “operator” under the reach of chapter 27 of title 31, and therefore, the terms “operating” or “driving” under R.I. Gen. Laws 31-27-1.2, 31-27-2.6 and 31-11-18 can encompass a passenger in a moving motor vehicle who seizes the wheel from the driver and steers the vehicle.The Supreme Court vacated the judgment of the superior court granting a motion to dismiss several counts set forth in a criminal information against Defendant for lack of probable cause pursuant to Rule 9.1 of the superior court rules of criminal procedure. Specifically, the trial justice declared that Defendant could not have violated the statutes at issue because Defendant - a back-seat passenger - was not operating or driving the motor vehicle when he grabbed the steering wheel and turned it, causing the vehicle to roll over. The Supreme Court held (1) by steering the direction of a moving vehicle, Defendant placed himself in the realm of the vehicle’s operator; and (2) this conduct can support a prosecution for violating sections 31-27-1.2, 31-27-2.6 and 31-11-18. View "State v. Peters" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree murder. The court held (1) even though Defendant’s trial commenced after the 180 days required by the Interstate Agreement on Detainers Act (IAD), Defendant’s federal sentence’s expiration nullified any rights he had under the IAD, and the delay in bringing the case to trial was a result of Defendant’s own pretrial motions; (2) the trial justice did not err in denying Defendant’s motions to suppress the seizure of his cell phone and the records of that cell phone, as well as other evidence retrieved from his apartment; (3) Defendant’s argument that the trial justice erred in allowing the admission of statements he made while he was in the hospital was waived; and (4) the sentence imposed on Defendant was not unduly harsh or unwarranted. View "State v. Tejeda" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of first-degree robbery following a jury-waived trial. On appeal, Defendant argued that the trial justice misconstrued the complainant’s testimony as to who confronted him and also erred in relying on a witness’s prior witness statements where her inability to read rendered her unable to effectively acknowledge her prior statements. The Supreme Court disagreed, holding (1) the trial justice, in summarizing the complainant’s testimony, accurately recounted it; and (2) because the witness was capable of recognizing her prior statements and could do so through the means the prosecutor used, the trial justice did not misconceive or overlook evidence. View "State v. Padilla" on Justia Law

The Supreme Court affirmed Defendant’s conviction of first-degree murder, discharging a firearm during a crime of violence, resulting in a death, and other crimes. On appeal, Defendant argued that the trial justice erred when he (1) denied Defendant’s request to order the State to produce the investigative notes of a detective with the Providence Police Department because Defendant was entitled to the notes pursuant to Rule 16 of the Superior Court Rules of Criminal Procedure and Brady v. Maryland, 373 U.S. 83 (1963); and (2) denied Defendant’s motion for a new trial. The Supreme Court held (1) no Brady or Rule 16 argument regarding the investigative notes was preserved for appeal; and (2) the trial justice did not err by overlooking or misconceiving material evidence in denying Defendant’s motion for a new trial. View "State v. Blandino" on Justia Law

Plaintiffs filed a complaint against Brown University and the City of Providence. In count one of their complaint Plaintiffs sought a declaration that the university’s construction of an artificial turf field hockey field with attendant bleachers, electronic scoreboard, press box, and public-address system was an unlawful use under the Providence zoning ordinance. The superior court granted summary judgment to Defendants as to count one. The Supreme Court vacated the judgment of the superior court, holding that the hearing justice erred in finding that Plaintiffs had no standing with respect to count one because, as abutting property owners, Plaintiffs clearly established an articulable injury in fact. View "Key v. Brown University" on Justia Law

Plaintiffs claimed that the sale of property without their consent to an entity of which Defendants were principals, was fraudulent. Plaintiffs also named as a defendant the title insurance and escrow agent in connection with the sale of the property. The superior court granted summary judgment in favor of all defendants. The Supreme Court affirmed the judgment in part and vacated it in part, holding (1) the hearing justice erred in determining that there was no factual issue regarding damages, and summary judgment is vacated as to the individual defendants to the extent that Plaintiffs may show damages for lost profits sustained in their individual capacities only; (2) the superior court properly granted summary judgment for the individual defendants as to Plaintiffs’ tortious interference with a contractual relationship claims, intentional interference with prospective contractual relations claims, breach of contract claims, fraud claims, and civil conspiracy claims; and (3) the judgment is affirmed in favor of the title company in all respects. View "Fogarty v. Palumbo" on Justia Law

In this commercial property dispute between a landlord, Roadepot, LLC and Keyserton, LLC (collectively, Roadepot), and a tenant, Home Depot, U.S.A., Inc., regarding sewer assessment charges, the Supreme Court affirmed in part and vacated in part judgments of the superior court. The Supreme Court held that the superior court (1) properly granted partial summary judgment in favor of Home Depot obligating Roadepot to pay the disputed sewer assessment charges; (2) the superior court erred in requiring Roadepot to reimburse Home Depot for sewer assessment charges paid by Home Depot before September 17, 2009; and (3) did not err in limiting Home Depot’s request for prejudgment interest and denying its claim for late fees on the sewer assessment charges. View "Roadepot, LLC et al. v. Home Depot, U.S.A., Inc." on Justia Law

The Supreme Court vacated the judgments of conviction entered in the superior court following a jury trial convicting Defendant of three counts of assault with a dangerous weapon and one count of carrying a pistol without a license. The Supreme Court held (1) the superior court justice erred in denying Defendant’s motion to suppress evidence seized by police during a warrantless search of Defendant’s home because the state failed to overcome the presumption of unreasonableness that accompanies every warrantless entry into a home; and (2) the admission of the unlawfully seized evidence was not harmless beyond a reasonable doubt. View "State v. Terzian" on Justia Law

The Supreme Court affirmed the judgment of the superior court following a jury verdict in favor of Plaintiff on a single claim of employment discrimination based on national origin. Both parties appealed the judgment. The Supreme Court denied and dismissed all appeals, holding that the superior court justice (1) did not err in instructing the jury on the law of evidentiary presumptions and its application to this discrimination claim; (2) properly weighed the evidence and did not invade the province of the jury; and (3) did not err when she vacated the jury’s finding that Plaintiff failed to mitigate his damages. Further, Plaintiff was not entitled to judgment as a matter of law on a separate count in the complaint that also alleged employment discrimination. View "Yangambi v. Providence School Board" on Justia Law

The Supreme Court vacated the decree of the family court as it pertained to Mother. The decree found that Mother failed to provide Daughter with a minimum degree of care or guardianship, that Child was without proper parental care and supervision, that Mother inflicted or allowed to be inflicted upon Daughter physical injury, and that Mother created or allowed to be created a substantial risk of physical injury to Daughter. Specifically, the Supreme Court held that the evidence presented was insufficient to permit a reasonable inference to be drawn that Mother abused and negligent Child. View "In re Adrina T." on Justia Law