Justia Rhode Island Supreme Court Opinion Summaries

R.I. Gen. Laws 10-6-2 means that the release of the master from liability also releases the servant.The Supreme Court affirmed the judgment of the superior court granting summary judgment for Defendants in this negligence case filed against two nurses. Plaintiff’s complaint was nearly identical to the one she had brought against Tavares Pediatric Center and later settled. In their motion for summary judgment, Defendants argued that Plaintiff’s claims were barred by R.I. Gen. Laws 10-6-2, which provides “that a master and servant or principal and agent shall be considered a single tortfeasor.” Specifically, Defendants maintained that because they and Tavares stood in a master-servant relationship, they should be considered a single tortfeasor and thus released from liability pursuant to Plaintiff’s release of Tavares from liability. The trial justice agreed. The Supreme Court affirmed, holding that section 10-6-2 foreclosed Plaintiff’s claims in this case. View "Hall v. Hornby" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting judgment as a matter of law in favor of Defendants in this employment discrimination action.Plaintiff, a former employee of the Town of Lincoln School Department, filed a complaint against the Town of Lincoln, Lincoln School Committee, and the Town’s Finance Director, alleging that she was discriminated against because she advocated for education services for her disabled son, who was a student in the Lincoln school system. The case went to trial. After both sides rested, the trial justice granted Defendants’ motion for judgment as a matter of law. The Supreme Court affirmed, holding that Plaintiff failed to provide sufficient evidence such that a reasonable jury could find that Lincoln’s actions were retaliation for Plaintiff’s advocacy efforts for her son. View "Azar v. Town of Lincoln" on Justia Law

From this point forward, Shatney v. State, 755 A.2d 130 (R.I. 2000), shall be deemed abrogated and inapplicable in any case involving both an initial application for postconviction relief and an applicant who has been sentenced to life without the possibility of parole.Appellant was convicted of first-degree murder and sentenced to life without the possibility of parole. The Supreme Court affirmed. This appeal concerned Appellant’s second amended application for postconviction relief. The hearing justice dismissed Appellant’s application after a hearing. The Supreme Court vacated the judgment of the superior court, holding (1) Shatney and Tassone v. State, 42 A.3d 1277 (R.I. 2012) are inconsistent with each other and may not properly be permitted to coexist as it relates to life without parole cases; and (2) Appellant was not provided with the evidentiary hearing to which he was entitled pursuant to Tassone. View "Motyka v. State" on Justia Law

The Supreme Court affirmed the hearing justice’s denial of Appellant’s application for postconviction relief seeking leave to withdraw his guilty pleas to breaking and entering and larceny charges. The breaking and entering and larceny pleas were entered in 1994, and Appellant had since served his entire sentence with respect to those cases. The Supreme Court concluded that the relief Appellant sought was the vacating of his 2008 guilty plea to second-degree murder and the dismissal of his 2004 murder indictment. The Supreme Court held (1) the 2004 murder charge and Appellant’s eventual guilty plea were not properly before the court; and (2) Appellant’s contention of ineffective assistance of counsel was not properly before the court. View "Burke v. State" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Defendant’s motion for a new trial and her request to proceed pro se.Defendant was found guilty of one count of simple assault following a jury trial. After Defendant’s motion for a new trial was denied, Defendant appealed. The Supreme Court affirmed, holding (1) the evidence was sufficient to support Defendant’s conviction, and therefore, the trial justice did not err in denying Defendant’s motion for a new trial; and (2) the trial justice did not err in concluding that Defendant had not made the “requisite intelligent and knowing decision to discharge counsel” and in therefore denying Defendant’s request to discharge her attorneys. View "State v. Withers" on Justia Law

The Supreme Court affirmed the judgment of the superior court finding that Defendant violated the terms of his probation, sentencing him to serve sixteen years in prison, and denying Defendant’s motion for reconsideration. The Supreme Court held (1) the hearing justice did not act arbitrarily or capriciously in finding a witness to be a credible witness at the probation-violation hearing; (2) the hearing justice did not err in finding that Defendant did not keep the peace or act with good behavior and in thus denying Defendant’s motion for reconsideration; and (3) the hearing justice did not abuse his discretion in executing the remaining sixteen years of Defendant’s suspended sentence. View "Neufville v. State" on Justia Law

In this criminal case in which Defendant was convicted of several crimes, the Supreme Court affirmed the judgment of the superior court denying Defendant’s motion for judgment of acquittal on the count of conspiracy to commit the crime of breaking and entering and refusing to grant a new trial on the breaking and entering a dwelling without consent charge. The court held (1) Defendant’s motion for a judgment of acquittal on the crime of conspiracy was properly denied because abundant and direct evidence was introduced from which a fact-finder could find that Defendant agreed to enter the dwelling; and (2) Defendant did not properly raise his argument before the trial justice regarding the breaking and entering charge, and therefore, this issue was waived. View "State v. Huntley" on Justia Law

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