Justia Rhode Island Supreme Court Opinion Summaries

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

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