Justia Rhode Island Supreme Court Opinion Summaries

Defendant entered a plea of nolo contendere to the charges of burglary, breaking and entering, and receiving stolen goods. Defendant filed an application for postconviction relief, alleging several grounds for relief regarding the voluntariness of his plea and the performance of his trial counsel. After a hearing, the superior court denied Defendant’s application for postconviction relief, finding that Defendant failed to carry his burden of proof and establish his claim and that Defendant’s testimony was self-serving and not credible. The Supreme Court affirmed, holding that the trial justice did not err in its judgment. View "Lopes v. State" on Justia Law

Plaintiffs, David Miller and Miller’s Auto Body, alleged that they were subject to a malicious investigation into suspected insurance fraud that Defendants, three insurance companies, believed was taking place at Plaintiffs’ auto-body shop. Miller was charged with, among other charges, four counts of insurance fraud. The criminal information was dismissed by the Attorney General, but the dismissal was conditioned on an agreement between Miller and the Attorney General requiring Miller to execute a general liability release in favor of Defendants. More than one year after executing the release, Plaintiffs filed a complaint against Defendants. The trial court granted pretrial summary judgment for Defendants on the majority of Plaintiffs’ claims. Only Plaintiffs’ abuse-of-process claim went to trial. The jury returned verdicts in favor of Plaintiff against the two remaining defendants. The trial court subsequently granted judgment as a matter of law in favor of one defendant but denied the other defendant’s motion for judgment as a matter of law. The Supreme Court affirmed in part and reversed in part, holding that the release executed by Miller before he initiated suit barred all his claims against the defendants. View "Miller v. Metro. Prop. & Cas. Ins. Co." on Justia Law

After a jury trial, Defendant was convicted of one count of second-degree child molestation. The Supreme Court affirmed the judgment, holding that the trial justice did not err in (1) denying Defendant’s motion to suppress an incriminating confession he gave to the police while in custody because the statement was given voluntarily; (2) permitting an attending physician at a child protection program who had examined the victim on the night of the incident to testify regarding the explanation of a normal examination over defense counsel’s objection; and (3) denying Defendant’s motion for judgment of acquittal, as there was sufficient evidence to support the conviction. View "State v. Armour" on Justia Law

Atwood Health Properties, LLC contracted with Calson Construction Company to construct a medical office building. Calson engaged Gem Plumbing & Heating Co., Inc. (GEM) as a subcontractor to design and install a heating, ventilation, and air conditioning (HVAC) system. Five years after the project was completed, Atwood sold the building to Atwood Medical Properties, LLC (AMP). When AMP experienced compressor failures in the HVAC system, AMP filed suit against Atwood. Atwood paid for a new HVAC system and initiated arbitration proceedings against Calson to recover its costs. Calson, in turn, initiated an arbitration proceeding against GEM for indemnification under the parties’ contract. The two arbitration proceedings were consolidated. The arbitrator concluded that Calson should pay Atwood $358,223 and that GEM should pay Calson that same amount. The superior court confirmed the arbitration award. GEM appealed. The Supreme Court affirmed, holding that the trial justice properly confirmed the arbitration award. View "Atwood Health Props., LLC v. Calson Constr. Co." on Justia Law

After Plaintiff underwent cervical disk replacement surgery at Rhode Island Hospital she suffered a stroke caused by a vertebral artery dissection. Dr. Gita Pensa at Newport Hospital treated Plaintiff when she first complained of pain due to the stroke, but Plaintiff was later discharged from the hospital. Plaintiff filed this medical malpractice action against Newport Hospital, Dr. Pensa, and NewPort Emergency Physicians, Inc. (collectively, Defendants), alleging negligence and lack of informed consent. After a three-week trial, the jury returned a verdict in favor of Defendants, finding that Plaintiff had failed to prove that Dr. Pensa had breached the standard of care. The Supreme Court vacated the judgment and remanded for a new trial, holding that the trial justice’s erroneous admission into evidence of three documents during the voir dire of Plaintiff’s standard-of-care expert, combined with the questionable wording of one question on the jury verdict form, was sufficiently prejudicial to warrant a new trial. View "O’Connor v. Newport Hosp." on Justia Law

Frank Corrente was employed by the City of Providence during two separate time periods. Following a federal investigation, Corrente was convicted of six felony counts stemming from his employment during the second time period. After a hearing conducted pursuant to the “Honorable Service Ordinance” (HSO) of the City of Providence Code of Ordinances, the Retirement Board of the Employees’ Retirement System of the City of Providence voted to reduce Corrente’s pension benefits. The Board then filed a civil action in the superior court requesting a confirmation of its decision. The mayor and the City of Providence were allowed to intervene. The superior court subsequently entered an order confirming the Board’s decision to reduce Corrente’s pension. The intervenors appealed. The Supreme Court vacated the judgment of the superior court, holding that because this case was brought pursuant to the HSO and was adjudicated in the superior court prior to the enactment of R.I. Gen Laws 36-10.1-5, which vests the superior court with jurisdiction to review pending proceedings under a municipal ordinance, the superior court lacked subject-matter jurisdiction and, therefore, the final judgment was void. Remanded. View "Ret. Bd. of Employees’ Ret. Sys. of City of Providence v. Corrente" on Justia Law

After a jury trial, Defendant was found guilty of one count of delivery of a controlled substance (cocaine) and was sentenced to five years’ incarceration. The Supreme Court affirmed, holding that the trial justice did not err in (1) denying Defendant’s motion in limine to bar the testimony of two detectives; (2) instructing the jury; (3) failing to include certain portions of testimony during a read back to the jury; (4) denying Defendant’s motion for judgment of acquittal; and (5) denying Defendant’s motion for a new trial. View "State v. Rodriguez" on Justia Law

After a jury trial, Defendant was convicted of first-degree felony murder and conspiracy to commit robbery. The Supreme Court affirmed, holding (1) the trial justice did not abuse his discretion in denying Defendant’s motion to pass the case due to an alleged discovery violation pursuant to Sup. Ct. R. Crim. P. 16 because, although Defendant framed the issue as one of insufficient disclosure, Rule 16 was, in fact, not implicated; and (2) the trial justice articulated adequate grounds for denying Defendant’s motion for a new trial and neither overlooked not misconceived material evidence, nor was otherwise clearly wrong, in making his decision. View "State v. Tully" on Justia Law

The Narragansett Indian Tribe (Tribe) filed a complaint against the State seeking a declaration that the Casino Act must be invalidated because it is unconstitutionally vague or because it otherwise violates the non-delegation doctrine enunciated in R.I. Const. art. VI, 1 and 2. UTGR, Inc. subsequently intervened as a defendant. The superior court found in favor of Defendants, concluding that the Casino Act was not facially unconstitutional. The Supreme Court affirmed, holding that, based on the strong presumption of constitutionality and the heavy burden of mounting a facial challenge, it could not be said that the Casino Act is facially unconstitutional. View "Narragansett Indian Tribe v. State" on Justia Law

Plaintiff, Renewable Resources, Inc., purchased the Potter Hill Mill, which was slated for demolition. Plaintiff and the Town of Westerly subsequently entered into a memorandum of agreement (MOA) in which Plaintiff pledged to meet a series of conditions to stave off demolition. Due to Plaintiff’s failure to expeditiously pursue its development plan, the Town began requesting proposals for the mill’s demolition. Plaintiff subsequently filed this action seeking a preliminary injunction and a permanent injunction against the Town barring demolition of the mill. A superior court justice entered a preliminary injunction order. The superior court later vacated the preliminary injunction and permitted the Town to issue a demolition order, concluding that Plaintiff had breached the MOA. In a subsequent judgment, the superior court dismissed the remaining counts of Plaintiff’s complaint. The Supreme Court affirmed, holding that the hearing justice acted within his discretion in vacating the preliminary injunction. View "Renewable Res., Inc. v. Town of Westerly" on Justia Law