Justia Rhode Island Supreme Court Opinion Summaries

Landlords filed an eviction action against Tenant. Eventually, the parties settled the eviction action by a stipulation that was signed by the district court judge. Thereafter, Tenant filed a negligence action alleging that Landlords failed to maintain the house free from toxic mold and fungus and that the mold ruined Tenant’s personal property. Landlords filed a motion in limine to prevent Tenant from entering the parties’ stipulation into evidence to prove causation in the negligence action and moved for summary judgment. The hearing justice granted Landlords’ motion in limine, barring the admission of the district court stipulation. The court then granted summary judgment for Defendants, ruling that Tenant could offer no other evidence of causation. The Supreme Court affirmed, holding (1) the hearing justice correctly granted the motion in limine, as nothing in the stipulation established that Landlords caused mold to accumulate on Tenant’s personal property; and (2) because Tenant conceded that there was no other evidence on the element of causation, the hearing justice correctly granted Landlords’ motion for summary judgment. View "Curreri v. Saint" on Justia Law

After a jury-waived trial, Defendant was convicted of five counts of stalking. The trial justice imposed a sentence of probation on each count, to run concurrently. The Supreme Court affirmed, holding (1) the trial justice did not err when she denied Defendant’s motion to dismiss because he was “without knowledge that his actions were disturbing”; (2) the trial justice did not err when she denied Defendant’s motion to dismiss counts three through five because the State failed to call three of the five complainants to testify; and (3) Defendant’s remaining arguments on appeal were not properly before the Supreme Court. View "State v. Kolsoi" on Justia Law

After a jury trial, Defendant was convicted of first-degree child molestation. The Supreme Court vacated the conviction and remanded for a new trial, determining that Defendant’s right to counsel was violated by the admission at trial of a statement he made to an agent of the state. After a second trial, the jury found Defendant guilty of first-degree child molestation. The trial justice sentenced Defendant to life imprisonment. The Supreme Court affirmed, holding (1) the forty-five-month delay between the return of the record to the superior court after Oliveira I and the commencement of Defendant’s retrial did not violate Defendant’s right to a speedy trial; and (2) the trial justice did not abuse his discretion in admitting certain out-of-court statements into evidence. View "State v. Oliveira" on Justia Law

In 2011, Plaintiff purchased a condominium unit at a condominium association lien foreclosure sale. In 2013, Plaintiff filed suit seeking to quiet title to the unit in his name. Plaintiff also sought declaratory and injunctive relief to prevent a foreclosure by Defendant, the prior owner’s first mortgage holder. The superior court dismissed Plaintiff’s complaint for failure to state a claim, concluding that Plaintiff took title to the property subject to Defendant’s mortgage. The Supreme Court reversed, holding that a condominium foreclosure sale conducted pursuant to the Rhode Island Condominium Act extinguishes a prior-recorded first mortgage on the unit following the mortgagee’s failure to exercise the right of redemption provided for in R.I. Gen. Laws 34-36.1-3.21(c). Remanded. View "Twenty Eleven, LLC v. Botelho" on Justia Law

Plaintiff was a school bus driver employed by Durham School Services (Durham), a private bus company. Citing a “Driver Withdrawal” provision from its contract with Durham for transportation of school students, the Town of Johnston School Department formally requested to not have Plaintiff transport students of the Johnston Public Schools. Lomastro was subsequently terminated. Plaintiff filed a complaint against the interim superintendent for the Town of Johnston and the director of facilities and transportation of Johnston public schools (collectively, Defendants), claiming that Defendants intentionally interfered with her contract with her employer. The hearing justice granted summary judgment in favor of Plaintiffs. The Supreme Court affirmed, holding that Plaintiff failed to provide evidence that the school department invoked its contractual right to withdraw its approval of Plaintiff as a driver without justification, which prevented Plaintiff from establishing a prima facie case of intentional interference with contractual relations. Therefore, the hearing justice did not err in granting summary judgment in favor of Defendants. View "Lomastro v. Iacovelli" on Justia Law

After a jury trial, Defendant was convicted of one count of felony domestic assault, two counts of assault with a dangerous weapon, and one count of simple domestic assault after previously having been convicted twice of domestic assault. The Supreme Court affirmed. Defendant later filed an application for postconviction relief, alleging that his trial counsel was ineffective because he stipulated to the fact that Defendant had two prior convictions for domestic violence in the presence of the jury. The Supreme Court affirmed, holding that trial counsel’s performance was not deficient, and even if Defendant were able to establish that his trial counsel was ineffective, Defendant’s right to a fair trial was not prejudiced by his trial counsel’s conduct. View "Snell v. State" on Justia Law

In 2003, Robert Loppi purchased a life insurance policy from United Investors Life Insurance Co. in which he initially named Marilyn Loppi, his wife, as the beneficiary. In 2008, after Marilyn filed for divorce from Robert, Robert applied to United Investors to change the beneficiary on his life insurance policy to his uncle, David Loppi. In 2009, during the course of the divorce proceeding, the family court entered an interlocutory order ordering that Robert’s life insurance policies be cashed in and that the cash surrender value be divided equally between Robert and Marilyn. Before Robert complied with the interlocutory order, Robert died. Thereafter, United Investors declined to pay the life insurance death benefit to either David or Marilyn. David filed this action seeking a declaratory judgment that he alone was entitled to the life insurance policy death benefit. The hearing justice granted David’s petition for declaratory judgment stating that David was entitled to 100 percent of the policy proceeds. The Supreme Court affirmed, holding that Marilyn was not entitled to any portion of the life insurance proceeds at issue. View "Loppi v. United Investors Life Ins. Co." on Justia Law

The Department of Children, Youth and Families (DCYF) filed petitions in Family Court alleging that Respondent had abused and neglected his two minor children and sought to terminate Respondent’s parental rights to both children. After consolidating the neglect and termination petitions for trial, the family court granted DCYF’s petitions and terminated Respondent’s parental rights to his two children. The Supreme Court affirmed, holding (1) the trial justice did not infringe Respondent’s due process rights when she rendered her decision to terminate Respondent’s parental rights immediately after she had appointed substitute counsel; and (2) the trial justice did not err by finding that DCYF had proved by clear and convincing evidence that Respondent was unfit to parent his two minor children. View "In re Jake G." on Justia Law

Plaintiff was injured when he fell down the stairs in his residence. Plaintiff filed a negligence action against Defendants, his landlords, alleging that Defendants failed to maintain the premises in a clean and safe condition. After a trial, the jury returned a verdict for Defendants. The superior court entered judgment in accordance with the verdict. Plaintiff appealed, arguing that the trial justice erred by denying his motion to pass the case due to jury prejudice. The Supreme Court affirmed, holding that the trial justice did not commit reversible error by rejecting Plaintiff’s motion to pass the case due to juror misconduct. View "Roma v. Moreira" on Justia Law

After a jury trial, Defendant was found guilty of three counts of first degree sexual assault and one count of assault with the intent to commit a sexual assault. Defendant appealed, arguing that the trial justice erred in permitting the State to impeach him with a prior conviction for assault and denying his motion for a new trial. The Supreme Court affirmed, holding (1) the trial justice did not abuse his discretion in concluding that Defendant’s assault conviction was admissible to impeach Defendant’s credibility; and (2) the trial justice was neither clearly wrong nor misconceived or overlooked material evidence in denying Defendant’s motion for a new trial. View "State v. Swiridowsky" on Justia Law