Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court vacated an order of the superior court denying the State’s request to adjudge Anthony Parrillo a probation violator based upon the hearing justice’s finding that Parrillo was no longer on probation at the time that he allegedly committed the offense of felony assault. The Court held (1) Parrillo was on probation and subject to being adjudged at the time he allegedly committed felony assault; (2) the hearing justice did not commit an error of law when he held that the doctrine of equitable estoppel did not bar the state from seeking to adjudge Parrillo a probation violator; and (3) the case must be remanded so that a hearing justice may address Parrillo’s due process argument in the first instance. View "State v. Parrillo" on Justia Law

The Supreme Court held that the trial justice did not err in finding that a 1909 Plat and Indenture did not reveal manifest intent to dedicate an over two-mile stretch of beach in the Misquamicut area of Westerly, Rhode Island to the public. The Court affirmed the trial court’s judgment in favor of the current beachfront landowners in the disputed area, holding that the trial justice did not err in finding that the evidence the State put forth - including the 1909 Plat and Indenture and and the extrinsic evidence - failed to demonstrate manifest intent by the Plattors to dedicate the beach area to the public. View "Kilmartin v. Barbuto" on Justia Law

After a jury trial, Defendant was convicted of one count of first-degree sexual assault and four counts of second-degree child molestation sexual assault. The Supreme Court affirmed the judgments of conviction, holding that the superior court did not commit reversible error in (1) denying Defendant’s motion to pass the case after the State alluded to an “empty chair”; (2) failing to exclude the victim’s testimony that she had witnessed Defendant inappropriately touching another small child after the child not be located in order to corroborate the allegation; and (3) denying Defendant’s motion for judgment of acquittal on two counts in the indictment. View "State v. Cavanaugh" on Justia Law

After a jury trial, Defendant was convicted on three separate counts of embezzlement and one count of conspiracy to commit embezzlement. Defendant filed a motion for a new trial, arguing that the evidence was not sufficient to prove his guilt beyond a reasonable doubt. The trial justice denied the motion. Defendant appealed, arguing that the trial justice erred in denying his motion for a new trial and in misconceiving the evidence, and in admitting certain evidence that Defendant alleged was irrelevant and unfairly prejudicial. The Supreme Court affirmed, holding (1) the trial justice conducted the appropriate analysis and was not clearly wrong in denying Defendant’s motion for a new trial; and (2) the trial justice was not clearly wrong in finding that the probative value of the evidence at issue outweighed its prejudicial effect. View "State v. McDonald" on Justia Law

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