Justia Rhode Island Supreme Court Opinion Summaries

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

After Strine Printing Company terminated Richard Bisbano’s employment, Bisbano filed an eight count complaint against Strine Printing and its president, alleging, inter alia, wrongful termination. During the pendency of that lawsuit, the parties disagreed about the exact amount of commissions that Strine owed Bisbano. The federal district court granted Defendants’ motion for summary judgment on all counts. Bisbano subsequently filed another lawsuit against Strine Printing and Menasha Packaging Company, LLC in superior court, alleging unpaid commissions. The trial justice ruled in favor of Defendants, concluding that the three-year statute of limitations contained in Rhode Island’s Payment of Wages Act barred the claim and that res judicata barred Bisbano’s contract claims. The Supreme Court affirmed, holding (1) this action was barred by the statute of limitations contained in the Payment of Wages Act; and (2) because the statute of limitations issue is dispositive, the Court shall not address the issue of res judicata. View "Bisbano v. Strine Printing Co., Inc." on Justia Law

After a jury trial, Defendant was convicted of first-degree murder, failure to report a death with the intention of concealing a crime, obstruction of a firefighter while in the execution of his duty, and violation of a no-contact order. Defendant filed a motion for a new trial, which the trial justice denied. The Supreme Court upheld the trial justice’s denial of Defendant’s motion for a new trial, holding that, based on the Court’s review of the record and the trial justice’s application of the required three-step analysis, and after consideration of Defendant’s contentions, the trial justice was neither clearly wrong nor misconceived or overlooked material evidence when she denied Defendant’s motion for a new trial. View "State v. Greenslit" on Justia Law

Plaintiff filed a multi-count complaint against Defendants - the Town of Narragansett, the treasurer for the town, the town police department, and two police officers - alleging, among other things, assault and battery, false arrest, and gross negligence or misconduct. The superior court ultimately entered summary judgment in favor of Defendants. Plaintiff appealed and further appealed the denial of multiple pretrial motions. The Supreme Court (1) vacated the judgment of the superior court with respect to its grant of summary judgment on Plaintiff’s claim of assault and battery, holding that the assault and battery claim was not fit for resolution by summary judgment; and (2) otherwise affirmed, holding that none of Plaintiff’s other claims withstood summary judgment and that there was no error in the denial of Plaintiff’s pretrial motions. View "Albanese v. Town of Narragansett" on Justia Law

Plaintiff filed a complaint against APG Security-RI, LLC (APG) and employees/agents of APG (collectively, Defendants) alleging that when she was employed as a security guard by APG, Defendants violated the employer drug testing statute (EDTS) by requiring her to submit to a drug test and subsequently terminating her employment based on the result of that test. Plaintiff sought damages pursuant to both the EDTS and Conn. Gen. Stat. 9-1-2. The hearing justice dismissed Plaintiff’s complaint, finding that the three-year statute of limitations in Conn. Gen. Stat. 9-1-14(b) governed Plaintiff’s cause of action. At issue on appeal was whether the ten-year period of limitation as provided in Conn. Gen. Stat. 9-1-13(a) or the three-year period of limitation as provided in section 9-1-14(b) applied to Plaintiff’s action. The Supreme Court affirmed, holding that actions brought pursuant to the EDTS and section 9-1-2 are subject to the three-year statute of limitations provided in section 9-1-14(b). View "Goddard v. APG Security-RI, LLC" on Justia Law

In a contested enforcement action, the Department of Environmental Management (DEM) ordered Power Test Realty Company Limited Partnership to remediate a site onto and under which petroleum had been released and imposed an administrative penalty. A hearing justice with the superior court affirmed. Power Test filed a writ of certiorari, arguing that the superior court erred in imposing liability upon it because it did not cause the discharge of petroleum, there was insufficient evidence demonstrating that it had knowledge of the leaching petroleum, and it owned only a portion of the contaminated site. The Supreme Court affirmed, holding (1) Power Test was correctly held liable under the OPCA even where Power Test did not cause the initial discharge of contaminants; (2) there was legally competent evidence to conclude that Power Test had knowledge that its property was the source of petroleum contamination; and (3) the superior court properly determined that DEM did not err in holding Power Test liable for remediating both its own property and a nearby parcel. View "Power Test Realty Co. Ltd. P’ship v. Coit" on Justia Law