Justia Rhode Island Supreme Court Opinion Summaries

Petitioner filed an application for a license to carry a concealed weapon. The Chief of Police for the City of East Providence denied the application. Petitioner sought review of the denial of his application pursuant to the Administrative Procedures Act and later added a request for mandamus relief. The superior court dismissed the action, determining that it lacked subject matter jurisdiction to entertain Petitioner’s appeal. Petitioner subsequently filed a petition for writ of certiorari with the Supreme Court. The Supreme Court granted the petition and quashed the decision denying Petitioner’s application for a license to carry a concealed weapon, holding (1) the Chief of Police's conclusions for denying the license were either insufficient or incorrect; and (2) the license denial could not properly be predicated on remote events resulting in Petitioner’s arrest on charges that were ultimately dismissed. View "Gadomski v. Taveres" on Justia Law

Defendant pled nolo contendere to uttering or delivering checks in an amount exceeding $1500 with intent to defraud, misappropriating property, and obtaining goods valued at more than $500 by false pretenses with intent to cheat or defraud. Defendant was ordered to pay $95,000 in restitution, in monthly installments of $500. Defendant later moved to reduce her monthly installments, claiming that she was only able to pay $237 per month and that, therefore, her payments should be reduced. The superior court denied Defendant’s request, concluding that Defendant had failed to establish that she was financially unable to make the restitution payments. The Supreme Court affirmed, holding that Defendant failed to meet her burden of proving an inability to maintain payments of $500 per month. View "State v. Rosenbaum" on Justia Law

Plaintiff and Defendants in this action were business owners with abutting properties. The disputed property in this case was a diagonal path through Plaintiff’s driveway to the business located on Defendants’ premises, which was regularly traveled by large delivery trucks. In 2013, Plaintiff filed a complaint against Defendants, seeking, among other relief, injunctive relief enjoining Defendants from trespassing onto, interfering with, obstructing, or blocking Plaintiff’s business. Defendants counterclaimed for trespass and also sought injunctive relief. The hearing justice granted Plaintiff’s request for preliminary injunctive relief, denied Defendants’ request for injunctive relief, and declared that Plaintiff owned and had the right to use and control the property in question. The Supreme Court affirmed, holding that the hearing justice did not abuse his discretion in finding that Plaintiff stood to suffer irreparable harm if relief were not granted and in therefore granting Plaintiff’s request for preliminary injunctive relief. View "Gianfrancesco v. A.R. Bilodeau, Inc." on Justia Law

Plaintiff filed a negligence action against the Town of South Kingstown stemming from an injury she sustained at a Town-owned park while she was a spectator at a little league baseball game. Specifically, Plaintiff alleged that the Town was negligent in maintaining the park. The superior court granted summary judgment in favor of the Town, concluding that the Recreational Use Statute (RUS) barred Plaintiff’s suit. The Supreme Court affirmed, holding that the hearing justice (1) did not err by applying the RUS to Plaintiff’s case; (2) did not err in refusing to apply the Minn. Stat. 32-6-5(a)(1) exception to the RUS to Plaintiff’s claim; and (3) properly applied the RUS in granting the Town’s motion for summary judgment. View "Carlson v. Town of South Kingstown" on Justia Law

In 2011, the Town of Middletown issued an invitation for bids on a drainage improvement project. Two contractors submitted bids, including HK&S Construction Holding Corp., which provided the lowest bid. Woodard & Curran, Inc. recommended against awarding HK&S the project and in favor of negotiating a contract with the second bidder. The town counsel concluded that HK&S’s bid was non-responsive and awarded the contract to the second bidder. Plaintiff filed a complaint against the Town and Woodard & Curran alleging, among other claims, that the Town violated state and local law when it denied the contract award for the project. The superior court granted summary judgment for Defendants. The Supreme Court affirmed, holding (1) there was no error in disposing of HK&S’s claims against the Town in summary judgment where HK&S failed to submit a responsive bid; and (2) HK&S’s claim of negligence against Woodard & Curran also failed. View "HK&S Constr. Holding Corp. v. Dible" on Justia Law

Defendant was charged with eleven offenses in a single indictment, most notably murder. After a jury trial, guilty verdicts were returned on all counts. The trial court sentenced Defendant to three consecutive life sentences plus an additional thirty-five consecutive nonparoleable years. The Supreme Court affirmed the judgments of conviction, holding (1) the trial justice did not abuse his discretion when he admitted character evidence under R.I. R. Evid. 404(b); and (2) the prosecutor did not make inappropriate or inflammatory comments during closing arguments that warranted a new trial. View "State v. Tucker" on Justia Law

After a jury trial, Defendant was found guilty of disorderly conduct and sentenced to six months’ incarceration. The Supreme Court affirmed the judgment of conviction and the denial of Defendant’s motion for a new trial and motion for a judgment of acquittal, holding (1) the trial justice did not err in denying Defendant’s motion for a new trial, as his speech rose to the level of the criminal offense with which he was charged; (2) there was sufficient evidence to convict Defendant; and (3) Defendant’s argument that the criminal complaint lodged against him was insufficient as a matter of law to place him on notice of the charge against him was not properly preserved for appellate review. View "State v. Matthews" on Justia Law

Plaintiffs filed this petition for the appointment of a guardian over their father. After the probate court denied Plaintiffs’ petition, Plaintiffs appealed. The superior court dismissed the complaint seeking review from the probate decision for Plaintiffs’ failure to adhere to statutory deadlines. Plaintiffs subsequently filed a motion pursuant to R.I. Gen. Laws 9-21-6 arguing that the dismissal of the probate court appeal was improper. The superior court denied the motion. The Supreme Court vacated the decision of the superior court, holding that Plaintiffs’ failure to have satisfied the requirements of R.I. Gen. Laws 33-23-1(a) constituted excusable neglect, and therefore, justice required that Plaintiffs’ appeal be allowed to proceed under section 9-21-6. View "Duffy v. Estate of Scire" on Justia Law

Plaintiff filed a civil action against a physician and his employer alleging that Defendants negligently failed to protect the confidentiality of his HIV test results and seeking to recover both compensatory and exemplary damages. The superior court granted Defendant's motion to strike Plaintiff’s claims for exemplary damages and severed Plaintiff’s claim for exemplary damages without holding an evidentiary hearing pursuant to Palmisano v. Toth. The Supreme Court quashed the order of the superior court, holding that the hearing justice erred failing to conduct an evidentiary hearing in accordance with the Court’s holding in Palmisano on Plaintiff’s claim for exemplary damages. Remanded. View "Sherman v. Ejnes" on Justia Law

The consolidated appeals arose out of a dispute between the Town of Johnston and Plaintiffs, former Town police officers who retired on injury disability. Plaintiffs filed complaints seeking declaratory and injunctive relief regarding entitlement to funds held in certain accounts. The Town refused to authorize distribution of amounts credited to the respective accounts, which were owned by the Town but maintained with Plaintiffs’ names and social security numbers. The superior court denied the Town’s motion for summary judgment and granted Plaintiffs’ cross-motions for summary judgment. The Supreme Court vacated the judgment of the superior court, holding that summary judgment in favor of Plaintiffs was not warranted because there were a multitude of factual issues that must be resolved. View "Ross v. Town of Johnston" on Justia Law