Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of assault with a dangerous weapon and other firearm-related offenses. Defendant appealed, arguing that the trial justice erred in denying his motion for a new trial because two key witnesses were not credible and the forensic evidence failed to conclusively link him to the shooting. The Supreme Court affirmed, holding that there was no basis for concluding that the trial justice committed clear error or that he overlooked or misconceived material evidence when he determined that the weight of the evidence supported the convictions and thus denied Defendant’s motion for a new trial. View "State v. Lopez" on Justia Law

In 2008, Plaintiffs filed this action seeking a declaratory judgment that the original master declaration creating Goat Island South - A Waterfront Condominium (GIS) was invalid and the second amended restated master declaration (SAR) was void ab initio. The hearing justice granted summary judgment in favor of Defendants on all claims, ruling that some claims were barred by res judicata because they could have been raised in earlier, related, litigation and that those claims were barred by the doctrine of estoppel by deed. The hearing justice also determined that the SAR was valid. The Supreme Court affirmed, holding (1) Plaintiffs’ first two claims were barred by the doctrines of res judicata and estoppel by deed; (2) the SAR is valid; (3) summary judgment in favor of the individually named GIS executive board defendants was appropriate; and (4) the hearing justice did not err in denying Plaintiffs’ motion to amend their complaint. View "IDC Props., Inc. v. Goat Island S. Condo. Ass’n" on Justia Law

Plaintiff was the beneficiary of a charitable trust. Included within the trust was a provision allowing Plaintiff to live rent-free in a certain property. When Plaintiff exercised his right to occupy the property and allowed his parents to move in in violation of the trust provisions, the trustee of the trust instituted legal action to evict Plaintiff and his parents. Plaintiff later filed a complaint against Defendant, the attorney who advised the trustee on the issue, alleging negligence and breach of fiduciary duty. The superior court dismissed Plaintiff’s claims, concluding that Defendant did not owe Plaintiff a duty while he represented the trustee. The Supreme Court affirmed, holding that the complaint was properly dismissed because Defendant did not owe Plaintiff a duty of care with regard to his representation of the trustee. View "Audette v. Poulin" on Justia Law

Plaintiffs - Jazmine Wray and Reginald Green - brought a negligence suit against Defendants - Roy and Antonio Green - as a result of a three-vehicle rear-end collision, claiming that, as a result of the collision, they experienced pain and suffering and incurred medical bills and lost wages. One of the defendants filed a motion for summary judgment. The motion was granted. The Supreme Court affirmed, holding that the superior court properly granted summary judgment in favor of the defendant, as Plaintiffs failed to present any evidence to prove that the defendant breached his duty of care. View "Wray v. Green" on Justia Law

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