Justia Rhode Island Supreme Court Opinion Summaries

Officer Tori-Lynn Heaton filed a grievance with the City of Cranston seeking to be allowed to retire from the Cranston Police Department at nineteen years, six months, and one day with her full twenty year pension. The City denied the grievance. Because Officer Heaton deferred her retirement until she had served the full twenty years, the issue in dispute at the arbitration was whether the City violated its collective bargaining agreement (CBA) with the International Brotherhood of Police Officers, Local 301 when it refused to credit Officer Heaton with a year of service for pension purposes. The arbitrator concluded that the City violated the ‘round-up’ rule of the CBA when it declined to credit Officer Heaton with a full additional year of service. Because there was no remedy available to Officer Heaton where she in fact completed a full twenty years of service before she retired, the arbitrator transmuted the arbitration award into a declaratory judgment. The trial justice granted the City’s motion to vacate, concluding that the arbitrator exceeded his authority when he fashioned an award on a dispute that was not arbitrable. The Supreme Court affirmed, holding that the decision of the arbitrator was improper and outside the bounds of the arbitrator’s authority. View "City of Cranston v. Int’l Brotherhood of Police Officers, Local 301" on Justia Law

After the parties’ divorce was granted and a final judgment of divorce was entered, William filed two motions in the family court seeking clarification of the division of assets, specifically as to two businesses that he and Valerie had operated during their marriage. The family court justice entered an order clarifying the final judgment of divorce and awarding the businesses to William. The court then entered an order adjudging Valerie in contempt and ordering her to comply with the final judgment of divorce. Included in the order was an award of interest against Valerie. The Supreme Court affirmed, holding (1) the chief judge of the family court did not err in assigning the motion for clarification to the family court justice who had presided over the original divorce action; (2) the family court justice did not err in issuing a decision on William’s motion for clarification; and (3) Valerie pointed to no valid basis for disturbing the contempt finding. View "Bremer v. Bremer" on Justia Law

Respondent was indicted for inflicting numerous injuries on his five-week-old daughter, resulting in the infant’s death. The Department of Children, Youth, and Families subsequently petitioned to terminate Respondent’s parental rights to his other child, a one-year-old son. After a trial, the family court terminated Father’s parental rights, finding that Respondent was an unfit parent due to the cruel and abusive nature of his conduct towards his daughter. The Supreme Court affirmed, holding that the trial justice’s finding that Respondent caused his daughter’s injuries was reasonable, and termination of Respondent’s parental rights to his son logically followed. View "In re Kristopher J." on Justia Law

Defendant was charged by information with stealing over $500 in violation of R.I. Gen. Laws 11-41-1 and 11-41-5 and soliciting another to receive stolen goods in violation of R.I. Gen. Laws 11-1-9. The amount of money in question was $714. Subsequently, the Governor signed into law an act amending section 11-41-5 to increase the threshold for felony larceny from $500 to $1500. During trial, Defendant sought to have the larceny count amended and the solicitation charge amended due to the legislative change. The trial court proceeded with the counts as charged and convicted Defendant of having committed larceny over $500 and having solicited another to receive stolen goods over $500. The Supreme Court affirmed, holding that the trial justice was correct in determining that the general savings clause, R.I. Gen. Laws 43-3-23, was applicable and that the changes to section 11-41-5 should not be applied retroactively. View "State v. Whiting" on Justia Law

Plaintiffs initiated a medical malpractice suit against numerous medical organizations and professionals twelve years after their daughter, Yendee, was born with a genetic disorder. Plaintiffs alleged negligence in the diagnosis and treatment relating to Yendee’s genetic disorder and also asserted their own claims for loss of consortium. The superior court granted Defendants’ motion to dismiss, concluding (1) Plaintiffs’ claims were barred by the statute of limitations set forth in R.I. Gen. Laws 9-1-14.1; and (2) in light of Yendee’s status as a minor, the tolling provision in section 9-1-14.1(1) would allow Yendee to file suit in the future on her own behalf upon reaching the age of majority, but Yendee’s parents would not be permitted to attach their loss-of-consortium claims to Yendee’s future suit. The Supreme Court affirmed, holding (1) under section 9-1-14.1(1), a minor’s parent or guardian may file suit on the minor’s behalf within three years of the occurrence or reasonable discovery of alleged malpractice, or the minor may file suit on her own behalf, but not until she reaches the age of majority; but (2) Plaintiffs’ claims may be asserted alongside Yendee’s claims if she elects to file suit upon reaching the age of majority. View "Ho-Rath v. Rhode Island Hospital" on Justia Law

When James Maddalena, a correctional officer with the Department of Corrections (DOC), admitted that another officer was smoking marijuana, in his presence, while on duty, Maddalena was terminated from employment with the DOC. The Rhode Island Brotherhood of Correctional Officers (RIBCO) filed a grievance on behalf of Maddalena in accordance with its collective bargaining agreement (CBA), contending that Maddalena was terminated without just cause. The matter proceeded to arbitration. An arbitrator determined that there was not just cause for Maddalena’s termination and provided that Maddalena be suspended without pay for sixty days. A justice of the superior court granted the DOC’s motion to vacate the arbitration award and denied RIBCO’s motion to confirm the award, determining that the arbitrator exceeded his authority and reached an irrational result because his decision was based upon a manifest disregard of the CBA. The Supreme Court affirmed, holding that the trial justice did not err in concluding that the arbitrator manifestly disregarded the CBA and that the arbitration award was irrational. View "State Dep’t of Corr. v. R.I. Brotherhood of Corr. Officers" on Justia Law

After a jury trial, Defendant was found guilty of one count of second-degree sexual assault. The Supreme Court affirmed, holding that the trial justice did not err in (1) denying Defendant’s motion to suppress the complainant’s out-of-court identification because there was not likelihood of misidentification and because the photo array was not unnecessarily suggestive; (2) denying Defendant’s motion for a new trial, as the trial justice followed the proper procedure for assessing a challenge to the weight of the evidence, and there was no indication that he overlooked or misconceived material evidence; and (3) denying Defendant’s request for a specific set of jury instructions. View "State v. Austin" on Justia Law

In 2010, Rudolph Bettez died. Rudolph was survived by his three sons - Robert, Ronald, and William - and his second wife, Joyce. Robert Bettez petitioned the probate court to admit Rudolph’s September 2009 to probate. In July 2012, The will was admitted to probate by a consent order. In August 2012, William Bettez appealed, alleging that Defendants - Robert, Ronald, and attorney Daniel Stone - collectively exerted undue influence over Rudolph in order that he exclude William from any share of his estate and that Rudolph lacked testamentary capacity when he executed the will. The superior court granted summary judgment for Defendants. The Supreme Court affirmed, holding that the trial justice did not err in its determination that no evidence of undue influence had been set forth in opposition to Defendants’ motion for summary judgment. View "Bettez v. Bettez" on Justia Law

Petitioners’ property directly abutted property identified as the Hines Road property, owned by Plaintiff. Plaintiff and the Town of Cumberland came to an agreement regarding a retaining wall on the Hines Road property in close proximity to Petitioners’ property. Plaintiff later filed a complaint against the Town to litigate issues relating to the agreement. Petitioners moved to intervene in the underlying superior court action. The hearing justice denied the motion to intervene, concluding that Petitioners were not entitled to intervention as a matter of right or to permissive intervention. The Supreme Court affirmed, holding (1) Petitioners’ status as abutting property owners did not ipso facto entitle them to intervene in this case as a matter of right; (2) the hearing justice did not err in ruling that Petitioners’ interest in the superior court action was “contingent” upon the agreement between Plaintiff and the Town; and (3) the hearing justice did not err in considering Petitioners’ failure to appeal from an adverse Board decision previously filed in regard to the agreement as one factor weighing against intervention in the underlying action. View "Hines Road, LLC v. Hall" on Justia Law

After a jury trial, Defendant was convicted of first-degree sexual assault and second-degree sexual assault and two counts each of assault with intent to commit second-degree sexual assault and of indecent solicitation of a minor. The Supreme Court affirmed the convictions, holding that the trial justice did not err in (1) denying Defendant’s motion for a bill of particulars, as the State provided Defendant with adequate notice of the charges; and (2) denying Defendant’s motion for a new trial, as the justice did not overlook or misconceive material evidence relating to a critical issue in this case. Remanded with directions to correct the final judgment to reflect the amended counts in the indictment. View "State v. Gregson" on Justia Law