Justia Rhode Island Supreme Court Opinion Summaries

After two separate trials, the family court entered decrees finding dependency as to Respondent’s sons, King and Saint, determining that the children were actually suffering or likely to suffer physical and/or emotional harm and that it was in the children’s best interest to be placed out-of-home. Both children were committed to the care, custody, and control of the Department of Children, Youth, and Families. Respondent appealed. The Supreme Court affirmed the decrees of the family court, holding that the trial justice’s findings of dependency as to both King and Saint were supported by clear and convincing evidence. View "In re King J." on Justia Law

In 1996, Matthew Cote accepted an employment opportunity with Richmond Ready-Mix (RRM) when John Aiello explained that Plaintiff could purchase RRM in the future. Over the years, Aiello repeatedly assured Cote that he would purchase RRM. In 2005, Aiello sold RRM to Peter Calcagni. Cote subsequently filed an action against the John and Anna-Maria Aiello (together, the Aiellos) alleging breach of an implied contract, promissory estoppel, unjust enrichment, fraud, and negligent misrepresentation. The trial justice found for the Aiellos on all claims, concluding that Cote failed to prove the existence of an implied contract to purchase RRM and that Aiello’s promises to Plaintiff did not support a claim for promissory estoppel. The Supreme Court affirmed, holding that the trial justice did not overlook or misconceive material evidence and was not otherwise clearly wrong in dismissing the complaint. View "Cote v. Aiello" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder, possessing a firearm after having previously been convicted of a violent crime, and other crimes. Defendant was sentenced to consecutive life sentences for first-degree murder and using a firearm during a violent crime. Defendant appealed, arguing that the trial justice erred in excluding the testimony of Stephen Bodden on the grounds that Bodden effectively invoked his Fifth Amendment privilege against self-incrimination. The Supreme Court affirmed, holding (1) Defendant’s appeal was not properly before the Court; and (2) nonetheless, the trial justice did not err when he ruled that Bodden properly invoked his Fifth Amendment privilege during the voir dire examination. View "State v. Barros" on Justia Law

Kevin Sweet executed a promissory note to Richard Boucher secured by a mortgage on real estate. Sweet defaulted on the note, and Boucher commenced foreclosure proceedings on the real estate. After a foreclosure sale held at a public auction, Boucher purchased the property for $35,000. Boucher then brought an action to collect the deficiency on the note. The superior court granted summary judgment for Boucher in the amount of $55,532, plus interest, attorney’s fees, and costs. A second justice vacated the summary judgment and, upon rehearing, granted summary judgment for Boucher in the amount of $48,155, plus interest and attorney’s fees. Sweet appealed, arguing that the hearing justice erred by not considering Boucher’s failure to adhere to the terms of sale. The Supreme Court affirmed, holding that the hearing justice properly grand summary judgment because Sweet failed to produce evidence demonstrating the impropriety of the foreclosure sale. View "Boucher v. Sweet" on Justia Law

After a jury-waived trial, Defendant was convicted of felony assault on a police officer, simple assault on a police officer, resisting arrest, driving under the influence of alcohol, and obstructing a police officer. During trial, the testimony each side presented diverged significantly, and the trial justice’s guilt assessment turned on his impression of witness credibility. The Supreme Court affirmed, holding that sufficient credible and competent evidence supported the trial justice’s guilt determinations on all counts beyond a reasonable doubt, and the trial justice did not overlook or misconceive any material evidence in reaching his decision. View "State v. Edwards" on Justia Law

The family court issued a decision granting the State’s petition to terminate Father’s parental rights to his two daughters. The family court justice finding by clear and convincing evidence that Father was an unfit parent, that the Department of Children, Youth, and Families (DCYF) had fulfilled its obligation to make reasonable efforts to reunify Father with his daughters, that Father failed to cooperate with the services offered by DCYF, and that it would be in the best interests of the children that they be adopted by their foster parents. The Supreme Court affirmed, holding that the family court justice’s findings were supported by legal and competent evidence. View "In re Briann A.T." on Justia Law

In 1992, a jury found Defendant guilty of murder in the first degree. The Supreme Court affirmed the conviction. In 2004, Defendant filed an application for postconviction relief pursuant to Rhode Island’s Innocence Protection Act. For almost a decade, various orders were entered and discovery took place. In 2015, Defendant filed a second amended application for postconviction relief. The hearing justice granted Defendant’s application for postconviction relief and vacated his conviction, finding two Brady violations based on the State’s suppression of favorable evidence and a due process violation resulting from the police department’s unduly suggestive interviewing of witnesses. The Supreme Court affirmed the superior court’s judgment vacating Defendant’s conviction, holding that the hearing justice erred in vacating Defendant’s conviction on the basis of the former prosecutor’s failure to disclose pretrial statements of one of the State’s witnesses, and this claim of error was dispositive of the State’s appeal. View "Tempest v. State" on Justia Law

In 1996, Defendant entered a plea of nolo contendere to several sex offenses and was sentenced to a term of incarceration. After Defendant was released on probation, he applied for a transfer of his probation supervision from Rhode Island to Pennsylvania pursuant to the Interstate Compact for Adult Offender Supervision (ICAOS). Pennsylvania accepted the transfer request and imposed additional conditions of supervision upon Defendant. Defendant violated the additional conditions. As a result, the State of Rhode Island filed a notice of probation violation. The probation violation hearing justice adjudged Defendant to be a probation violator, determining that ICAOS rules mandated that he treat the violations to which Defendant admitted as a violation of his Rhode Island probation. The hearing justice then executed eight years of Defendant’s suspended sentence and imposed new conditions of probation. The Supreme Court affirmed in part and vacated in part, holding (1) the hearing justice did not act arbitrarily and capriciously in finding that Defendant violated the terms and conditions of his probation; (2) the hearing justice did not abuse his discretion in ordering Defendant to serve eight years of his suspended sentence; but (3) in imposing two additional conditions, the hearing justice plainly exceeded his statutory jurisdiction. View "State v. Brown" on Justia Law

Petitioner, after more than fifteen years of service in the City of Providence Police Department, was injured while on duty. The Department concluded that Petitioner’s injury interfered with her ability to handle a firearm. Later that month, Petitioner applied to the City of Providence Retirement Board for accidental-disability retirement. The Board voted to deny Petitioner’s application, finding that Petitioner’s condition was correctable with surgery and that Petitioner failed to mitigate her injury by undergoing surgery. The Supreme Court quashed the Board’s decision, holding that the Providence Code of Ordinances does not require an otherwise eligible employee to mitigate her injury by undergoing a surgical procedure in order to qualify for an accidental-disability pension. Remanded. View "Prew v. Employee Ret. Sys. of City of Providence" on Justia Law

After a jury trial, Defendant was convicted of assault with a dangerous weapon and vandalism. Defendant appealed, arguing that the trial justice erred in granting the State’s motion to preclude Defendant from discussing self-defense in his closing argument and by refusing to instruct the jury on the law of self-defense. The Supreme Court vacated Defendant’s conviction for felony assault with a dangerous weapon, holding (1) the trial justice erred by refusing to include a self-defense instruction in the jury charge; and (2) the holding with respect to the felony assault conviction does not affect Defendant’s conviction for vandalism. View "State v. Soler" on Justia Law