Justia Rhode Island Supreme Court Opinion Summaries

Plaintiff filed a claim against Testator’s estate for $2 million. The superior court awarded Plaintiff the amount requested under the provisions of the Testator’s last will and testament. The hearing justice then reduced the $2 million by the proceeds of a life insurance policy, ultimately granting summary judgment to Plaintiff in the amount of $1,550,000. Thereafter, the hearing justice awarded Plaintiff the requested amount of attorney’s fees but denied her request for prejudgment interest. The Supreme Court vacated the judgment of the trial justice, holding that the trial justice erred in granting summary judgment where this matter required fact-finding and conclusions of law with respect to Testator’s intent because the will did not clearly specify under what circumstances Plaintiff was to receive the sum of $2 million or other amount; and (2) an earlier stipulation entered in the family court did not control the outcome of this case in accordance with the principles of res judicata and collateral estoppel. Remanded. View "Glassie v. Doucette" on Justia Law

In case concerning a lease dispute, the Supreme Court concluded that Plaintiff was not in privity of contract, either through a lease agreement or an attainment agreement, and could not challenge the validity of the original lease or any of its amendments. Plaintiff filed a four-count complaint against Defendants. The superior court granted Plaintiff’s motion for partial summary judgment with respect to the declarations sought. On the eve of trial, the superior court granted full summary judgment for Defendants and entered final judgment for Defendants, concluding that Plaintiff was not in privity of contract with Defendants and lacked standing to assert the allegations raised in its complaint. The Supreme Court affirmed. View "1112 Charles, L.P. v. Fornel Entertainment, Inc." on Justia Law

Plaintiff, the executrix of the estate of the decedent, brought a declaratory judgment action seeking a declaration that the estate was entitled to underinsured motorist coverage under a policy issued by Quincy Mutual policy. The motion justice determined that the decedent was “occupying” his owned-but-not-insured motorcycle at the time of his fatal injury, and therefore, an exclusion of the policy applied. Plaintiff appealed, arguing that summary judgment was inappropriate because the decedent was separated from his motorcycle at the time of his death and, therefore, was not occupying the motorcycle as that term was defined in the Quincy Mutual policy. The Supreme Court reversed, holding that a genuine issue of material fact existed as to what impact caused the decedent’s fatal injuries and the time or distance between them, precluding summary judgment. View "Jackson v. Quincy Mutual Fire Insurance Co." on Justia Law

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