Justia Rhode Island Supreme Court Opinion Summaries

Early in the morning of October 25, 2011, as she was leaving for work, Lora, was viciously attacked by a masked assailant in the front hall of her home and was severely cut on her face with a small blade. Lora subsequently identified her attacker as Breton, with whom she had previously had a two-year-long romantic relationship. Breton was charged with assault with a dangerous weapon and simple assault on Lora. A third count was for a simple assault against Lora’s daughter, which was alleged to have occurred on May 26, 2010. When the case was reached for trial, Breton was convicted of the two counts of assault against Lora, but acquitted of the third count. The Rhode Island Supreme Court affirmed, rejecting an argument that the trial justice misconstrued the evidence when he found Lora to be a more credible witness than the alibi witnesses produced by Breton, Breton’s mother and a family friend. View "State v. Breton" on Justia Law

Florez was convicted of one count of second-degree child molestation sexual assault (sexual contact with a person 14 years of age or under) in violation of G.L. 1956 11-37-8.3 and 11-37-8.4 and was sentenced to 20 years’ imprisonment, with eight years to serve and the remaining time suspended with probation. The Rhode Island Supreme Court affirmed, rejecting claims that the trial justice erred in denying his motion for a new trial; that the trial justice’s jury charge and verdict sheet were flawed in that they permitted the jury to return a non-unanimous guilty verdict; that the trial justice erred by allowing the state to improperly refresh the complainant’s recollection; and that the trial justice committed reversible error by declining to admit parts of the witness statement of the complainant’s father into evidence. View "State v. Florez" on Justia Law

In 2012, the Cranston Police Department filed delinquency petitions alleging that, when B.H. was 13 years old, he committed two offenses that, if committed by an adult, would constitute the offense of first-degree child molestation and one offense that, if committed by an adult, would constitute the offense of second-degree child molestation. The victims were 11-year-old boys.The Family Court found the B.H. delinquent for the violations under G.L. 1956 11-37-8.1 and 11-37-8.2. The Rhode Island Supreme Court remanded, finding that the evidence at the delinquency proceeding was insufficient to establish sexual penetration—an element of both of the charges of first-degree child molestation of which the respondent was adjudged to be delinquent. The court directed the Family Court to enter adjudications of delinquency on the lesser-included offense of second-degree child molestation sexual assault (second-degree child molestation). View "In the Matter of B.H." on Justia Law

Plaintiff brought this medical malpractice lawsuit against Defendants, his optometrist and his optometrist’s employer, arguing that his optometrist breach the duty of care to him because he failed to diagnose a detached retina, which resulted in permanent vision loss. The jury returned a verdict in favor of Defendants, concluding that although the optometrist violated the standard of care in treating Defendant, that violation was not the cause of Plaintiff’s vision loss. The Supreme Court vacated the judgment and remanded for a new trial, holding that the trial justice erred by restricting the testimony of Plaintiff’s causation expert, and Plaintiff was entitled to a new trial on all issues. View "Ribeiro v. Rhode Island Eye Inst." on Justia Law

Plaintiff purchased certain property at a tax sale and then filed a petition to foreclose tax lien seeking to foreclose Bank’s right of redemption with respect to the property. Bank did not timely file an answer after its receipt of the petition. Plaintiff subsequently filed a motion for entry of default and final decree and a motion for decree pro confesso. Thereafter, Bank filed a motion to file a late answer and its response to the petition, which contained an offer to redeem. The trial justice granted Bank’s motion to file a late answer and Bank’s request for redemption. The court then entered judgment allowing Bank and redeem the property and setting forth the amount of redemption. The Supreme Court vacated the judgment of the superior court, holding (1) Bank’s motion to file a late answer should have been denied because there was no good cause shown for Bank’s failure to comply with the deadline set out in the petition; and (2) accordingly, Bank was in default and should not have been permitted to redeem the property. View "Conley v. Fontaine" on Justia Law

Plaintiff filed a complaint against Defendants alleging breach of fiduciary duty resulting from oppressive conduct, breach of fiduciary duty resulting from self-dealing, fraud in the inducement, and negligent misrepresentation. During trial, Plaintiff produced 155 pages of documents that had not been produced to Defendants during discovery. Defendants argued that they were denied a fair trial because the information contained in the documents would have permitted them to properly cross-examine Plaintiff. The district court dismissed the case with prejudice pursuant to Sup. Ct. R. Civ. P. 37(b) as a sanction for the mid-trial production of documents. The court subsequently denied Plaintiff’s motion to vacate the order of dismissal under Sup. Ct. R. Civ. P. 60(b). The Supreme Court affirmed, holding (1) the trial justice did not err in dismissing Plaintiff’s claim with prejudice pursuant to Rule 37; and (2) the trial justice did not abuse his discretion in denying Rule 60(b) relief. View "Joachim v. Straight Line Prods., LLC" on Justia Law

Defendant was charged with one count of possession of cocaine. Defendant moved to suppress physical evidence seized and statements made to the police, arguing that he was arrested without probable cause and that the subsequent search of his jacket was unconstitutional. The trial justice denied the motion, determining that police had probable cause to arrest Defendant. After a trial, the jury convicted Defendant of the charged offense. The Supreme Court vacated the judgment of conviction, holding that Defendant’s arrest was not supported by probable cause, and therefore, his motion to suppress should have been granted. View "State v. Ray" on Justia Law

In 2010, the General Assembly amended R.I. Gen. Laws 12-19-18 to provide that a sentence of imprisonment after a finding of probation violation shall be quashed and the imprisonment terminated in certain circumstances occurring after a judgment of probation violation. In 2009, Defendant pled nolo contendere to felony assault. In 2012, while on probation, Defendant was charged with second-degree sexual assault and robbery. The State filed a notice of probation violation based on the conduct giving rise to these charges. The trial justice declared Defendant to be a probation violator and ordered him to serve two years of his suspended sentence. Thereafter, Defendant was acquitted on both counts. Defendant filed a motion to terminate his imprisonment. The trial justice denied Defendant’s motion, concluding (1) application of section 12-19-18(b) required impermissible retroactive application of the 2010 amendment; and (2) even if applied prospectively, section 12-19-18(b) constituted an unconstitutional exercise of judicial power by the General Assembly. The Supreme Court vacated the judgment of the superior court, holding (1) this case entails prospective, not retroactive, application of the statute; and (2) the trial justice was without authority to decide, sua sponte, a constitutional issue that was not raised by the parties. View "State v. Beaudoin" on Justia Law

In 2009, Defendant pled nolo contendere to one count of felony assault. Defendant was sentenced to a term of imprisonment and the balance suspended with probation. In 2012, the State filed a notice of probation violation alleging that Defendant failed to comply with the condition of his probation that he keep the peace and be of good behavior. After a violation hearing, the hearing justice found that Defendant had violated the conditions of his probation and ordered Defendant to serve two years of his suspended sentence. The Supreme Court affirmed, holding that the hearing justice acted neither arbitrarily nor capriciously in finding that Defendant violated the conditions of his probation on the basis of the evidence presented by the State. View "State v. Beaudoin" on Justia Law

Five corporate plaintiffs sued the East Greenwich Fire District and the Town of East Greenwich alleging that Defendants’ imposition and collection of development impact fees from developers who applied for a building permit to develop land within the Town violated Rhode Island’s Development Impact fee Act (RIDIFA). The fire district adopted the schedule of impact fees by a resolution rather than through an ordinance. The superior court entered judgment in favor of Defendants on all counts. Plaintiffs appealed, arguing that Defendants did not have the authority to impose development impact fees and, if they did, the process by which they imposed the fees was deficient. The Supreme Court vacated the judgment of the superior court, holding that the resolution adopted by the fire district was invalid because it did not comply with either RIDIFA’s mandate that the fees be imposed through an ordinance or the Town’s notice and public-hearing requirements for the enactment of ordinances. View "5750 Post Road Med. Offices, LLC v. East Greenwich Fire Dist." on Justia Law