Justia Rhode Island Supreme Court Opinion Summaries

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

Defendant was convicted of constructive possession of a firearm after a conviction for a crime of violence. Defendant appealed. The Supreme Court affirmed, holding (1) the trial justice did not err in refusing to suppress Defendant’s post-arrest statement to the police with respect to the gun at issue in this case; (2) Defendant waived the issue of whether the trial judge erred in declining to submit to the jury the issue of the voluntariness of Defendant’s alleged statement with respect to the gun at issue; and (3) the trial justice did not err in denying Defendant’s motion for judgment of acquittal and motion for a new trial. View "State v. Yon" on Justia Law

The trial court did not err in declining to suppress the statements Defendant had given tot he police.Defendant was convicted on two counts of first-degree sexual assault. The trial court sentenced Defendant to twenty-five years on both counts, to run concurrently. Defendant appealed the denial of his motion to suppress the statements that he had given to the police, arguing that the State failed to meet its burden of demonstrating, by clear and convincing evidence, that he knowingly, intelligently, and voluntarily waived his constitutional rights under Miranda v. Arizona, 384 U.S. 436 (1966). The Supreme Court affirmed, holding (1) the hearing justice’s finding that Defendant’s statements were not invited by the police but were voluntary statements was correct; (2) Defendant’s post-Miranda statements were admissible because the detectives did not engage in the “question first” interrogation technique found unconstitutional in Missouri v. Seibert, 542 U.S. 600 (2004); and (3) there was no evidence that Defendant failed to comprehend the nature of his rights or the consequences of abandoning them when he made statements while in custody at the police station. View "State v. Sabourin" on Justia Law

Defendant was charged via a criminal information with breaking and entering a dwelling. After a trial, the trial justice granted Defendant’s motion to pass the case based on based on a comment made by the prosecutor during closing argument. Thereafter, Defendant filed a motion to dismiss the information on grounds of double jeopardy. The trial justice denied Defendant’s motion to dismiss, ruling that the State’s actions were not intended to goad Defendant into seeking a mistrial. The Supreme Court affirmed, holding that the trial justice did not err in determining that the prosecutor did not intentionally goad Defendant into moving for a mistrial. View "State v. Corleto" on Justia Law

Defendant pleaded nolo contendere to assault in a dwelling house with intent to murder while armed with a dangerous weapon and carrying a pistol on or about his person without a license. While Defendant was on parole, he was arrested and charged with domestic assault and failure to relinquish a telephone. Also while on parole Defendant was charged with breaking and entering. After a hearing, Defendant admitted that he violated the terms and conditions of his probation. Defendant later filed an application for postconviction relief alleging that he was denied the effective assistance of counsel at the probation violation hearing and that he did not knowingly, intelligently, and voluntarily admit a violation of probation. A hearing justice denied Defendant’s application for postconviction relief. The Supreme Court affirmed, holding (1) any alleged deficient performance by Defendant’s attorney was not so prejudicial as to deprive Defendant to a fair trial; and (2) Defendant’s admission was made knowingly, intelligently, and voluntarily. View "Gomes v. State" on Justia Law

The raise-or-waive rule barred consideration of the argument brought before the Supreme Court on appeal in this breach of a promissory note case.In a prior appeal in this case, the Supreme Court affirmed a judgment of the superior court in favor of the Judgment Creditor against the Judgment Debtors in the amount of nearly $4 million plus post-judgment interest on claims for breach of a promissory note and breach of a guaranty of that note. In this second appeal, one of the judgment debtors (Judgment Debtor) appealed from an order of the superior court directing that Judgment Creditor be substituted for Judgment Debtor as the party to litigate Judgment Debtor’s claims in receivership proceedings. The Supreme Court affirmed, holding that the issue raised on appeal was not properly before the court due to the raise-or-waive rule. View "Tri-Town Construction Co. v. Commerce Park Associates 12, LLC" on Justia Law