Justia Rhode Island Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the superior court, following a bench trial, convicting Defendants, James and Melissa Pelletier, of violating Tiverton Zoning Ordinance article IV, section 13(a) for manufacturing compost in an R-80 zone. The court held (1) the trial justice did not overlook or misconceive material evidence and was not clearly wrong in finding that Defendants violated the zoning ordinance beyond a reasonable doubt; (2) processing compost on the property at issue is not a permitted accessory use; and (3) the ordinance at issue is not void for vagueness. View "State ex rel Town of Tiverton v. Pelletier" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendant, Deutsche Bank National Trust Company, on Plaintiff’s complaint alleging that Defendant was unable to foreclose on Plaintiff’s mortgage because it did not hold Plaintiff’s note. The superior court determined that Defendant was in fact the mortgagee and was entitled to foreclose on the mortgage. The Supreme Court upheld the hearing justice’s grant of Defendant’s motion for summary judgment, holding that because a mortgagee need not hold the note in order to foreclose on a property, Defendant, the mortgagee, was entitled to foreclose on Plaintiff’s property. View "Pimentel v. Deutsche Bank National Trust Co." on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Plaintiff’s motion for a new trial after the jury returned a verdict in favor of Defendants in this medical malpractice action.Plaintiff’s claim against Defendants arose from an injury she alleged she suffered when she underwent an emergency cesarean section. The jury returned a verdict for Defendants. Plaintiff moved for a new trial. The trial justice denied the motion, concluding that reasonable minds could differ as to whether Plaintiff’s doctor’s conduct fell below the appropriate standard of care. The Supreme Court affirmed, holding (1) the trial justice did not err in determining that reasonable minds could differ as to whether the doctor complied with the standard of care; and (2) the trial justice did not abuse his discretion in his evidentiary rulings. View "Cappuccilli v. Carcieri" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting the City of Providence’s motion for summary judgment in this lawsuit filed by Lehigh Cement Co. seeking to recover approximately $500,000 in real estate taxes billed and collected by the city from 2006 to 2009. The court held (1) the hearing justice did not err in granting summary judgment on Lehigh’s claim under R.I. Gen. Laws 44-5-23, as the statute does not provide relief to a taxpayer; (2) summary judgment on Lehigh’s claim under the fair distribution clause of the Rhode Island Constitution was appropriate; and (3) the hearing justice did not err in granting summary judgment on Lehigh’s claim under R.I. Gen. Laws 44-5-27. View "Lehigh Cement Co. v. Quinn" on Justia Law

The Supreme Court affirmed the judgment of the superior court finding that Defendant violated the terms and conditions of his probation and ordering him to serve at the Adult Correctional Institutions (ACI) six of the seven years of his previously suspended sentence. Defendant appealed, arguing that the hearing justice acted arbitrarily and capriciously in adjudicating him to be a probation violator because the record in this case did not substantiate the finding that he failed to keep the peace or remain on good behavior when he made certain statements in the course of telephone calls from prison, where he had been detained. The Supreme Court reversed, holding that the hearing justice’s decision adjudging Defendant to be a probation violator was neither arbitrary nor capricious. View "State v. Mosley" on Justia Law