Justia Rhode Island Supreme Court Opinion Summaries

At dispute in this case was an allegedly underfunded trust that was created by the decedent, Donelson Glassie (Donelson), for the benefit of his daughter, the late Jacquelin Glassie (Jacquelin), in accordance with a property settlement agreement between Jacquelin’s divorcing parents, Donelson and Marcia Glassie. After Donelson died, Jacquelin filed a claim against his estate, alleging that her father breached the property settlement agreement by failing to properly fund the trust. The claim was denied. Jacquelin then filed this action alleging breach of contract in that Donelson failed to carry out the provisions of the property settlement agreement. Jacquelin then died. Alison Glassie was appointed executrix of Jacqulin’s estate and was substituted as plaintiff in this action. The superior court granted summary judgment in favor of the defendant, the executor of Donelson’s estate, concluding that the plaintiff lacked standing to sue the estate because, generally, only a trustee may institute an action on behalf of the beneficiaries of a trust. The Supreme Court affirmed, holding that the plaintiff lacked the requisite standing to sue her father’s estate for benefits she would have received based on her status as the beneficiary of the trust. View "Glassie v. Doucette" on Justia Law

After a jury trial, Defendant was found guilty of three counts of child molestation against his stepdaughter. The Supreme Court affirmed the judgment of the superior court, holding (1) the trial justice did not abuse his discretion when he allowed the admission of evidence of other wrongful acts under R.I. R. Evid. 404(b); (2) the trial justice did not err when he allowed the State to introduce Donna Hogan as a witness where Hogan was not listed in the State’s response to discovery; (3) the trial justice did not err when he precluded defense counsel from cross-examining Donna Hogan about specific instances of conduct concerning the complaining witness’s character for untruthfulness; (4) the trial justice did not err when he allowed Hogan to testify as to the meaning of the complaining witness’s body language and demeanor; (5) the trial justice did not err when he denied Defendant’s motion for judgment of acquittal; and (6) the jury instructions were proper. View "State v. Thibedau" on Justia Law

Plaintiff slipped and fell while she was working as a contract nurse at the Rhode Island Veterans Home. Plaintiff brought suit against the State. After a trial, the jury awarded Plaintiff $500,000. The trial justice granted the State a remittitur, lessening Plaintiff’s award to $382,000. The prejudgment interest award, however, increased the judgment to $631,373.66. The Supreme Court affirmed, holding (1) the trial justice did not err in finding the the public-duty doctrine inapplicable; (2) the trial justice correctly rejected the application of the statutory tort cap in R.I. Gen. Laws 9-31-2; (3) the prejudgment interest award was not erroneous; (4) the trial justice properly denied the State’s motion for judgment as a matter of law; and (5) the State’s argument that the trial justice erred in failing to instruct the jury on comparative negligence was not preserved for review. View "Roach v. State" on Justia Law

Plaintiff Stephen Limoges claimed that he suffered significant pulmonary injuries in a chemical spill. Plaintiffs brought suit against three different entities, including Arden Engineering Constructors, LLC, alleging, inter alia, that they were individually and collectively responsible for Plaintiff’s injuries. Arden filed a motion for summary judgment, which the hearing justice granted. Plaintiffs appealed, arguing that that the hearing justice made an improper credibility assessment about the affidavit of their expert and because he overlooked material issues of fact that were in dispute. The Supreme Court vacated the judgment of the superior court, holding that Plaintiffs’ expert’s affidavit, combined with the documents that were available to the hearing justice, raised a material question of fact as to whether Arden was responsible for Plaintiff’s injury. View "Limoges v. Nalco Co." on Justia Law

Plaintiff filed a negligence suit against Defendant after falling and sustaining injuries while on Defendant’s property. After a trial, the jury returned a verdict in Plaintiff’s favor, finding Defendant to be sixty-five percent negligent. Defendant filed motions for judgment as a matter of law and for a new trial. The trial justice granted both motions, concluding that the elements of Plaintiff’s negligence claim had not been established by the evidence adduced at trial. The Supreme Court affirmed, holding that the evidence adduced at trial did not support a verdict in Plaintiff’s favor. View "Lemont v. Estate of Mary Della Ventura" on Justia Law

After a jury trial, Defendant was convicted of two counts of felony assault and one count each of possession of a controlled substance, resisting arrest, and reckless driving. Defendant petitioned the Supreme Court for a writ of certiorari, arguing that the trial justice’s instructions to the jury at the conclusion of the parties’ final arguments constituted reversible error because the instructions impermissibly commented on the evidence and were misleading and bolstering. The Supreme Court affirmed the judgment of the trial court, holding that the trial justice’s jury instructions were acceptable and that the trial justice did not comment on the evidence or, in any other way, confuse or mislead the jury. View "State v. Angeles" on Justia Law

Defendant pled nolo contendere to one count of second-degree sexual assault and one count of intimidation of a witness in a criminal proceeding. Defendant filed an application for postconviction relief alleging that his sentence and conviction were unconstitutional due to the ineffective assistance of counsel. A hearing justice denied postconviction relief, concluding that Defendant made a knowing and intelligent plea at the time of his plea. The Supreme Court affirmed, holding (1) Defendant failed to provide the evidence required to support a claim of ineffective assistance of counsel; and (2) the justice who conducted the postconviction relief hearing did not overlook or misconceive material evidence in arriving at her findings. View "Njie v. State" on Justia Law

Carel Bainum was found guilty of willful trespass because of her unwelcome contact with a former resident in the dementia ward of the Coventry Health and Rehabilitation Center. Bainum then brought a civil action against the Coventry Police Department, alleging that her willful trespass conviction was the consequence of two malicious acts by the Department. The motion justice granted summary judgment in favor of the Department. The Supreme Court affirmed, holding that summary judgment was proper because Plaintiff’s malicious prosecution claim failed as a matter of law, and therefore, her civil-conspiracy claim must also fail. View "Bainum v. Coventry Police Department" on Justia Law

Jason Goffe and Michael Petrarca were high-speed racing when Goffe lost control of his vehicle and whirled into the eastbound lane. William Walmsley struck Goffe’s vehicle, killing Goffe and his passenger, Brendan O’Connell Roberti. Roberti’s parents (Plaintiffs) sued several defendants, including Walmsley. Because of settlement releases, Walmsley was the sole defendant who advanced to trial. A jury found Walmsley negligent and that his negligence was a proximate cause of Roberti’s death. Defendant moved for judgment as a matter of law, which the trial justice granted. Plaintiffs moved for a new trial and requested an additur to $250,000. The trial justice ruled conditionally that, if Defendant’s motion for judgment as a matter of law was overturned on appeal, he would grant Plaintiffs’ motion for additur. The Supreme Court vacated the superior court’s judgment and remanded for additional proceedings. On remand, Plaintiffs sought judgment against Walmsley for $250,000 per the additur. The hearing justice granted summary judgment for Defendant, finding that because Plaintiffs settled their claims against Goffe and Petrarca in the amount of $395,000, there was no basis for holding Walmsley individually liable for $250,000. The Supreme Court affirmed, holding that the Wrongful Death Act is subject to joint and several liability principles. View "O’Connell v. Walmsley" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder, one count of felony assault, and three counts of discharging a firearm during a crime of violence. The trial justice sentenced Defendant to four consecutive life sentences followed by two consecutive twenty-year sentences. The Supreme Court affirmed, holding that the trial justice (1) did not err in admitting into evidence of a high-capacity magazine seized from Defendant’s home; (2) did not violate Rule 16 of the Superior Court Rules of Criminal Procedure when he admitted certain testimony; (3) did not err in dismissing a certain juror pursuant to the State’s peremptory challenge; and (4) articulated sufficient reasoning and did not overlook or misconceive any critical issue when he found that there was sufficient evidence to support a conviction of first-degree murder. View "State v. Nichols" on Justia Law