Justia Rhode Island Supreme Court Opinion Summaries
State v. Angeles
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
Posted in:
Criminal Law
Njie v. State
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
Bainum v. Coventry Police Department
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
Posted in:
Criminal Law, Personal Injury
O’Connell v. Walmsley
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
Posted in:
Native American Law, Personal Injury
State v. Nichols
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
Posted in:
Criminal Law
State v. Giard
Defendant pled nolo contendere to one count of felony assault and received a deferred sentence. Thereafter, Defendant was presented with a notice of violation based on an alleged act of second-degree child molestation of Jessica, Defendant’s niece. After a trial, the jury acquitted Defendant of second-degree child molestation. The hearing justice, however, imposed on Defendant a twenty-five-year sentence with five years to serve, concluding that, by his sexual contact with Jessica, Defendant had violated the conditions of his deferred sentence. The Supreme Court affirmed, holding that the hearing justice did not act unreasonably or arbitrarily in finding that a violation of the conditions of Defendant’s deferred sentence had occurred. View "State v. Giard" on Justia Law
Posted in:
Criminal Law
Walsh v. Lend Lease (US) Construction
Lend Lease (US) Construction was the general contractor on a project, and Rossi Electric Company, Inc. was a subcontractor. An employee of Rossi’s subcontractor was injured while working on the project and filed a negligence claim against Lend Lease. Lend Lease filed a third-party complaint against Rossi, alleging that, under the terms of a contract between the parties, Rossi was required to defend and indemnify Lend Lease. The superior court entered an order granting summary judgment for Rossi. The Supreme Court vacated the judgment of the superior court, holding that issues of material fact remained to be determined, and therefore, this case was not ripe for summary judgment. Remanded. View "Walsh v. Lend Lease (US) Construction" on Justia Law
Preservation Society of Newport County v. City Council of the City of Newport
The Preservation Society of Newport County and Newport Catering, Inc. (together, Petitioners) filed two applications for victualing licenses, proposing to sell pre-wrapped food prepared off-site, along with snacks and nonalcoholic drinks, at two historic mansions in the City of Newport. The City Council of the City of Newport (Respondent) denied the applications. Petitioners appealed, arguing that the Council exceeded its jurisdiction and applied inappropriate criteria in denying the victualing licenses. The Supreme Court quashed the decision of the Council and directed the Council to issue the licenses forthwith, absent any compelling evidence of significant health and/or safety issues, holding that the Council failed to provide factual findings and legal grounds to support its decision denying Petitioners’ applications for victualing licenses. View "Preservation Society of Newport County v. City Council of the City of Newport" on Justia Law
Posted in:
Government & Administrative Law
Faber v. McVay
Plaintiffs, Charles Faber and Karen Faber, filed suit against insurance agencies and related individuals, claiming insurance malpractice. Defendants moved for summary judgment on the basis that Plaintiffs’ claims were barred by the statute of limitations. Plaintiffs responded that the limitation period was tolled because Charles could not reasonably have discovered the alleged insurance malpractice until a date within the limitations period because a reasonable person does not read his or her insurance policies. Summary judgment was entered for Defendants on grounds that Plaintiffs’ claims were time-barred under the three-year limitation period for insurance malpractice claims. The Supreme Court affirmed, holding that Plaintiffs’ claims against Defendants were untimely. View "Faber v. McVay" on Justia Law
Posted in:
Insurance Law, Professional Malpractice & Ethics
Mancini v. City of Providence
This certified question concerned an action pending in federal court in which Plaintiff alleged that he was illegally denied a promotion in the Providence Police Department. At issue in this proceeding was Plaintiff’s count claiming that Chief of Police of the Providence Police Department was liable, in his individual capacity, for the City’s failure to have promoted Plaintiff in violation of section 28-5-7-(6) of the Rhode Island Fair Employment Practices Act. Clements moved to dismiss the count, arguing that section 28-5-7(6) does not provide for individual liability. The district court then certified to the Supreme Court the question at issue here. The Supreme Court answered that section 28-5-7(6) does not provide for the individual liability of an employee of a defendant employer. Remanded. View "Mancini v. City of Providence" on Justia Law
Posted in:
Labor & Employment Law