Justia Rhode Island Supreme Court Opinion Summaries

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

The Supreme Court affirmed Defendant’s convictions of-first degree murder and the discharge of a firearm while committing a crime of violence. On appeal, Defendant argued that the trial justice erred when “he refused to give an eyewitness identification jury instruction approved by this Court in State v. Werner, 851 A.2d 1093, 1002 (R.I. 2004).” The Supreme Court disagreed, holding that the trial court did not err and comported with case law when it denied Defendant’s request for a jury instruction on eyewitness identification, which instruction Defendant wished to be taken verbatim from Werner. View "State v. Fuentes" on Justia Law

The Supreme Court vacated Defendant’s convictions of three counts of first-degree murder, three counts of discharging a firearm while committing a crime of violence, and one count of conspiracy to commit robbery. Defendant was sixteen years old when he was identified as the shooter during an attempted robbery. Before trial, new information came to light, and the State’s theory of the case indicated that Defendant was not the shooter. On appeal, Defendant argued that the trial court erred by admitting R.I. R. Evid. 404(b) evidence. The Supreme Court agreed, holding that the evidence had slight probative value, if any at all, with respect with Defendant, and, moreover, was highly likely to have had an unduly prejudicial impact on the jury. Therefore, the admission of the evidence was not harmless beyond a reasonable doubt. View "State v. Husband" on Justia Law

Adam Correia was seriously injured after he and Edward Alexander went target shooting and Alexander accidentally shot Correia in the abdomen. Correia brought five claims against John and Theresa Bettencourt, the owners of the property where the accidental shooting occurred. At issue was whether John Bettencourt had a duty to exercise reasonable care to protect Correia from the negligence of a third party, Alexander. The superior court granted summary judgment to the Bettencourts on all counts. The Supreme Court affirmed, holding that no material facts were at issue in this case and that the facts presented did not give rise to the imposition of a duty upon Bettencourt. View "Correia v. Bettencourt" on Justia Law

The Supreme Court affirmed Defendant’s convictions for one count of first-degree robbery, two counts of felony assault, one count of second-degree murder, and one count of committing a crime of violence while possessing a firearm. On appeal, Defendant challenged the evidentiary rulings of the trial justice and the trial justice’s denial of his motion for a new trial. The Supreme Court affirmed, holding (1) there was no prejudicial error in the trial justice’s evidentiary rulings; and (2) the trial justice did not overlook or misconceive material evidence, nor was he otherwise clearly wrong, in denying Defendant’s motion for a new trial. View "State v. Adams" on Justia Law

Michael Beagan was terminated from his employment with Albert Kemperle, Inc. after his manager discovered a disparaging post Beagan had made about him on Facebook. The Rhode Island Department of Labor and Training (DLT) denied Beagan’s application for unemployment benefits, finding that he had been discharged for “disqualifying reasons” under R.I. Gen. Laws 28-44-18. The district court affirmed the DLT’s decision. The Supreme Court quashed the decision of the district court and remanded with directions to award Beagan unemployment benefits, holding that no legally competent evidence existed that Beagan’s Facebook post was connected to his work in the manner contemplated by section 28-44-18, and therefore, there was no legally competent evidence to support a finding that Beagan was ineligible for unemployment benefits. View "Beagan v. Rhode Island Department of Labor & Training, Board of Review" on Justia Law

Plaintiff, who was injured while rendering roadside aid as a Good Samaritan, was “occupying” the insured vehicle for purposes of underinsured motorist (UM) coverage and was therefore entitled to recover under the terms of a GEICO Insurance Agency, Inc. policy.Plaintiff was a passenger in a Saab driven by Gregory Hurst when the two witnessed an automobile collision. Plaintiff exited the Saab and was attempting to render assistance when she was struck by another car. Plaintiff settled a claim against the driver of the vehicle that hit her but claimed that she was not fully compensated for her injuries. Consequently, Plaintiff filed a claim with GEICO (Defendant) seeking relief through Hurst’s GEICO policy that insured the Saab. Defendant denied the claim on the ground that Plaintiff was not “occupying” the insured vehicle at the time of her injuries. Plaintiff then filed this action. The trial justice agreed with Defendant, concluding that Plaintiff could not recover UM benefits under the terms of the GEICO policy. The Supreme Court vacated the judgment of the superior court, holding that Plaintiff was entitled to recover under the terms of the policy. View "Hudson v. GEICO Insurance Agency, Inc." on Justia Law

The doctrine of collateral estoppel did not bar the state from prosecuting a chemical breath test refusal under R.I. Gen. Laws 31-37-2.1.Defendant was convicted of unlawful possession of marijuana and a chemical refusal. The Supreme Court remanded the case to the superior court for an evidentiary hearing on the issue of whether Defendant’s motion to dismiss on grounds of collateral estoppel was timely. The superior court found that Defendant’s motion was untimely filed but that there was good cause for the delay. Before the Supreme Court, Defendant argued that the state was collaterally estopped from prosecuting the chemical refusal because the facts at issue were decided in the Traffic Tribunal. The Supreme Court affirmed the judgment of conviction, holding that collateral estoppel did not apply under the circumstances of this case. View "State v. Pacheco" on Justia Law

Plaintiff slipped on a patch of black ice in the paved parking area adjacent to his apartment building, which was owned by Defendant. Plaintiff filed suit against Defendant, alleging that Defendant negligently maintained the premises and that Defendant’s negligence was the direct and proximate cause of Plaintiff’s shoulder injury. At the close of Plaintiff’s case, Defendant moved for judgment as a matter of law. Before sending the case to the jury, the trial justice granted Defendant’s motion. The Supreme Court vacated the judgment of the superior court, holding that the trial justice erred because there was enough evidence to send the case to the jury. View "Aubin v. MAG Realty, LLC" on Justia Law