Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of possession of a controlled substance with intent to deliver, possession of a firearm while in possession of a controlled substance with intent to deliver, and conspiracy to possess a controlled substance with intent to deliver. The Supreme Court vacated the judgment of conviction, holding that the trial justice erred in refusing to allow Defendant to make an opening statement to the jury without affording him the opportunity to articulate the nature of the purportedly affirmative evidence he intended to elicit on cross-examination of the state’s witnesses. View "State v. Martinez" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and related crimes. Defendant was sentenced to life imprisonment on the murder count. Defendant appealed, arguing that the trial court erred by denying his motion to suppress the confession he made to the police, denying his motion for a new trial, and making certain evidentiary rulings at trial. The Supreme Court affirmed, holding (1) the court properly denied Defendant’s motion to suppress; (2) the challenged evidentiary rulings were correctly made; and (3) the trial justice did not overlook or misconceive material evidence in denying Defendant’s motion for a new trial. View "State v. Garcia" on Justia Law

Plaintiff filed an application with the Coastal Resources Management Council (CRMC) seeking to expand his condominium unit. Defendants filed an objection to the proposal, asserting that Plaintiff did not own the property upon which he sought to expand his unit. CRMC denied the application. Plaintiff subsequently brought a complaint alleging slander of title and breach of contract and sought a declaratory judgment that he had the right to file his application with the CRMC. The trial justice granted summary judgment in favor of Defendants, concluding that Rhode Island’s anti-SLAPP statute protected them from liability for questioning Plaintiff’s ownership of the land in their communications with the CRMC. The Supreme Court affirmed. Defendants then filed a motion seeking attorney fees incurred in defending the anti-SLAPP judgment on appeal. The hearing justice awarded Defendants $8,924 in attorney’s fees in connection with the appeal. The Supreme Court affirmed the award of attorney's fees, holding (1) the issue of attorney’s fees was properly before the superior court; and (2) the superior court did not abuse his discretion in awarding attorney’s fees. View "Sisto v. America Condo. Ass’n, Inc." on Justia Law

Goat Island South Condominium (GIS) was comprised of three subcondominium residence areas - Harbor Houses Condominium (Harbor Houses), America Condominium (America), and Capella South Condominium (Capella). The Constellation Trust owned Unit 18 in Harbor Houses. Plaintiffs, America and Capella, filed an action against Defendants, the trustee of the Trust and Harbor Houses, seeking injunctive relief to bring a halt to the expansion of Unit 18 onto a limited common element. The trial justice concluded (1) Defendants were liable for breach of contract and for committing a common law trespass, (2) Plaintiffs’ allegation that Defendants breached restrictive covenants contained in the GIS Second Amended and Restated Declaration of Condominium (GIS SAR) was moot, and (3) Plaintiffs were not entitled to attorneys’ fees. The Supreme Court affirmed in part and vacated in part, holding (1) the trial justice erred in failing to award attorneys’ fees and costs to Plaintiffs based on the terms of the GIS SAR; and (2) the trial court did not otherwise err in its judgment. View "America Condo. Ass’n, Inc. v. Mardo" on Justia Law

Plaintiffs filed three petitions for relief from property tax assessments on their home for the tax years 2009 through 2011. The petitions and appeals were consolidated. The trial justice granted judgment in favor of Plaintiffs in all three appeals, concluding that Plaintiffs sustained their burden of proving that their property was overvalued by the tax assessor. The Supreme Court affirmed, holding (1) the trial justice did not err in determining that Plaintiffs met their burden of proving that the tax assessor’s valuation was above the fair market value; (2) there was sufficient evidence to support the trial justice’s valuation; and (3) the trial justice should have dismissed Plaintiffs’ third petition challenging their 2011 assessment based on Plaintiffs’ failure to timely file an account. Remanded. View "Whittemore v. Thompson" on Justia Law

Kathryn Manning (Plaintiff), individually and as administratrix of the estate of Michael Manning (Manning) and on behalf of her four minor children, brought this negligence and wrongful death action against Dr. Peter Bellafiore after Manning suffered a fatal stroke. After a lengthy discovery period, the case proceeded to trial. The jury returned a verdict in favor of Defendant. The trial justice subsequently granted Plaintiff’s motion for a new trial, and the Supreme Court affirmed. Thereafter, the trial justice granted Plaintiff’s motion to sanction both Defendant and the law firm that represented him at trial, White & Kelly, P.C. (WCK) under Rule 11 of the Superior Court Rules of Civil Procedure for their failure to make pretrial disclosures. The Supreme Court affirmed in part and reversed in part, holding (1) the trial justice did not abuse his discretion in finding that Dr. Bellafiore engaged in sanctionable misconduct; (2) the trial justice abused his discretion when he sanctioned WCK because the justice did not make a finding that the attorneys at WCK acted in “bad faith, vexatiously, wantonly, or for oppressive reasons”; and (3) the amount of sanctions imposed was based on an erroneous assessment of the evidence. View "Manning v. Bellafiore" on Justia Law

Plaintiff owned several units in a waterfront luxury condominium complex when an incident involving a frozen water pipe and its diluvial aftermath caused extensive property damage to several of the units. Plaintiff filed a complaint against the owners of one condominium unit as well as several construction defendants, who were involved in building the condominium, alleging negligence and diminution of value of Plaintiff’s property. Final judgment was entered for all defendants. The Supreme Court affirmed, holding that Plaintiff could not recover loss-of-use damages during the time that the condominium units were under repair because Plaintiff conceded that it had not incurred any economic loss as a result of Defendants’ negligent conduct and because it failed to raise any claims that would allow recovery despite an absence of an economic loss. View "Newstone Dev., LLC v. East Pacific, LLC" on Justia Law

In 2012, Applicant filed an amended application for postcoviction relief asserting that his convictions in four prior drug-offenses cases were the result of ineffective assistance of counsel because he had pled nolo contendere in each case rather than pursuing a motion to suppress evidence or going to trial. The hearing justice denied Applicant’s postconviction relief application, concluding that Applicant failed to prove that any of his attorneys’ performances were constitutionally deficient. The Supreme Court affirmed, holding that Applicant failed to demonstrate that any of his attorneys provided ineffective assistance of counsel in his previous cases. View "Lipscomb v. State" on Justia Law

In 2008, Brett Roy broke his neck when diving into a pond at World War II Veterans Memorial Park in Woonsocket. Roy and his wife (Plaintiffs) filed suit against the State, the Rhode Island Department of Environmental Management (DEM), and two DEM employees (collectively, the State), alleging negligence and premises liability. After a trial, the jury returned a verdict for the State, concluding that the State had not “willfully or maliciously failed to guard or warn against a dangerous condition, use, structure, or activity at the pond.” The trial court granted Plaintiffs’ motion for a new trial after denying both parties’ motions for judgment as a matter of law. The State appealed, arguing that the trial justice erred in granting Plaintiffs’ motion for a new trial and that the State owed no duty to Roy. Plaintiffs cross-appealed. The Supreme Court vacated the judgment of the superior court and remanded with instructions to enter judgment for the State, holding that the State bore no liability for Roy’s injuries, either because diving is an open and obvious danger or because it is protected under the Recreational Use Statute, and therefore, the trial justice erred in denying the State’s motion for judgment as a matter of law. View "Roy v. State" on Justia Law

An East Providence zoning officer issued a notice of violation, finding violations of a use variance that was granted in 1998 to the owner and operator of a construction and demolition debris processing facility known as Pond View Recycling. The East Providence Zoning Board of Review upheld the notice of violation. The owner and operator of Pond View appealed. The superior court reversed, concluding that the zoning board’s decision was “clearly erroneous and made upon unlawful procedure.” The City of East Providence and the zoning board sought review. The Supreme Court quashed the judgment of the superior court and remanded the case with instructions to enter judgment for the City, holding that the zoning board’s findings of fact were not clearly erroneous, and therefore, the trial justice erred by reversing the decision of the zoning board. View "Kenlin Props., LLC v. City of East Providence" on Justia Law