Justia Rhode Island Supreme Court Opinion Summaries

Defendant was charged with two counts of second-degree child molestation. After a jury trial, Defendant was convicted on Count 1 and acquitted on Count 2. Defendant appealed, arguing that the trial justice erred in his instructions to the jury and by employing the jury-verdict form. Specifically, Defendant asserted that the trial justice failed adequately to inform the jury of the distinction between Counts 1 and 2, which were identically worded. The Supreme Court affirmed the judgment of the superior court, holding that, while the issue was not properly preserved for review on appeal, it also lacked merit because there was no evidence in the record to indicate that the jury suffered from any confusion between Counts 1 and 2. View "State v. Hunt" on Justia Law

The Providence Journal Company and Amanda Milkovits (collectively, the Journal) requested records from the Rhode Island State Police concerning an investigation of an underage drinking incident at property owned by the then-Governor Lincoln Chafee. The Rhode Island Department of Public Safety Department denied the Journal’s records request. Thereafter, the Journal filed a complaint against the Department, the State Police, and the Commissioner of the Department (collectively, Defendants) alleging violations of Rhode Island’s Access to Public Records Act (APRA). The superior court granted summary judgment to Defendants, concluding that the requested documents were not subject to public disclosure pursuant to the APRA. The Supreme Court affirmed, holding that the records request was properly denied pursuant to the APRA. View "Providence Journal Co. v. R.I. Dep’t of Pub. Safety" on Justia Law

After a jury trial, Defendant was convicted of assault with a dangerous weapon. Defendant was sentenced to five years’ imprisonment, suspended, with five years of probation. The Supreme Court affirmed the judgment of conviction, holding (1) the trial justice did not err in barring testimony from one of the responding police officers, which concluded that Defendant was afraid of the complaining witness, on the grounds that the testimony was inadmissible hearsay; and (2) the trial justice did not overlook or misconceive material evidence or clearly err in denying Defendant’s motion for a new trial. View "State v. Williams" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and related crimes. Defendant appealed, arguing that the trial justice erred in (1) failing to grant his motion to suppress evidence that was obtained as a result of his warrantless arrest in his home, and (2) failing to remove two allegedly biased jurors from the jury or, in the alternative, to grant a mistrial. The Supreme Court vacated the judgment of the superior court and remanded for a new trial, holding (1) the trial justice erred in denying Defendant’s motion to suppress, as the warrantless entry into Defendant’s home was not consented to freely and voluntarily, and the State failed to establish the existence of exigent circumstances to justify the entry into the home; and (2) the error in this case was not harmless. Remanded for a new trial. View "State v. Gonzalez" on Justia Law

The Rhode Island Department of Transportation (RIDOT) condemned a parcel of real property owned by Richard Deeble and his wife for highway purposes. The Deebles subsequently died. RIDOT utilized only a portion of the condemned property in furtherance of the relocation of an interstate. Plaintiff, the Estate of Richard Deeble, sought declaratory and injunctive relief against RIDOT, asserting that should RIDOT seek to sell or lease the condemned property, the Estate was entitled to a right of first refusal to repurchase or lease the land in accordance with article 6, section 19 of the Rhode Island Constitution. The superior court justice concluded that the provisions of article 6, section 19 did not pass to the Estate. The Supreme Court affirmed, holding that the rights guaranteed by article 6, section 19 terminate upon the death of the original condemnee. View "Estate of Richard J. Deeble v. Dep’t of Transp." on Justia Law

Mark Van Hoesen was seriously injured when he fell from a deck. Van Hoesen and his wife (together, Plaintiffs) filed an amended complaint alleging negligence against Lloyd’s of London, the insurer of the contractor who constructed the deck. The trial court granted summary judgment for Lloyd’s on the grounds that the insurance policy had been canceled and had expired long before the injuries alleged in Plaintiffs’ complaint occurred. The Supreme Court affirmed, holding (1) from the terms of the contract, for Plaintiffs’ claims to be covered, the “bodily injury” must also have occurred during the policy period; and (2) therefore, the insurance company had no duty to provide coverage for the bodily injury that happened outside the policy period. View "Van Hoesen v. Lloyd’s of London" on Justia Law

At issue in this case was an inter vivos trust. The trust provided for three shares that were to be apportioned among the Settlor’s daughter and successor trustee, Lynne, the Settlor's son, Neil, and the Settlor's grandchildren, Kimberly and Jeffrey. Here, Kimberly sought to vacate an order of the superior court requiring that the disposition of funds held in trust for her be used to pay attorneys’ fees. The Supreme Court affirmed, holding (1) the trial justice did not err when he approved the first and final accounting of Lynne and when he approved the payment of the Settlor’s final debts and expenses, as well as administration costs, from the corpus of the trust; (2) the trial justice did not err in discharging and releasing Lynne from her fiduciary duty because Lynne did not breach that duty; (3) the trial justice did not abuse his discretion when he concluded that attorneys’ fees should be satisfied from Kimberly’s share of the trust; and (4) the trial justice did not violate Kimberly’s due process rights during certain hearings. View "In re Janet S. Bagdis Living Trust Agreement" on Justia Law

At dispute in this decade-old case was the various rice dishes offered for sale in the food court at the Providence Place Mall. These consolidated appeals represented the second and third times that the Supreme Court was asked to entertain fragmented issues. Cathay Cathay, Inc., Japan Cafe of Providence Place, Inc., Surf & Turf Grille, Inc., and Gourmet India all entered into lease agreements to operate restaurants in the food court. Each lease agreement set forth restrictions on the foods each restaurant could serve. Cathay Cathay and Surf & Turf (collectively Plaintiffs) brought this action against Rouse Providence, LLC, Gourmet India, and Japan Cafe seeking to enjoin the two restaurants from selling the foods to which they had alleged exclusive rights. Plaintiffs also requested that the court order Rouse to enforce its lease agreements with Cathay Cathay and Surf & Turf against Gourmet India and Japan Cafe, alleging that the restaurants violated their lease agreements by selling prohibited foods. After protracted litigation, a second trial justice entered partial final judgment in favor of Rouse. The Supreme Court vacated the partial final judgment, holding that the trial justice abused her discretion in determining that there was a previous adjudication on the merits of Plaintiffs’ contractual claims against Rouse. Remanded. View "Cathay Cathay, Inc. v. Vindalu, LLC" on Justia Law

After a jury trial, Defendant was convicted of one count of breaking and entering. The trial justice sentenced Defendant to a term of incarceration and also adjudged Defendant to be a habitual offender. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not err in (1) denying Defendant’s motion for a judgment of acquittal, as there was sufficient evidence to support Defendant’s conviction; (2) limiting the scope of Defendant's cross-examination of the State’s fingerprint expert; and (3) denying Defendant's motion for a new trial, as the trial justice performed the requisite analysis and provided an adequate rationale for denying the motion. View "State v. Isom" on Justia Law

Plaintiffs sought a dimensional variance by the Zoning Board of Review of the Town of Jamestown. After the Board denied the variance, Plaintiffs appealed. The superior court reversed the Board’s decision and granted Plaintiffs’ variance application. Thereafter, Plaintiffs moved for an award of reasonable litigation expenses under the Equal Access to Justice for Small Businesses and Individuals Act. The trial justice denied Plaintiffs’ motion, concluding that the Board was not an “agency” within the purview of the Act and that the hearing before the Board was not an “adjudicatory proceeding” as the term is defined in the Act. The Supreme Court quashed the judgment below, holding that the Board is an agency and that the hearing on Plaintiffs’ variance application was an adjudicatory proceeding on the Act. Remanded for written findings and conclusions with respect to the remaining prerequisites for relief. View "Tarbox v. Zoning Bd. of Review" on Justia Law