Justia Rhode Island Supreme Court Opinion Summaries

Plaintiff filed a pro se complaint against Defendants, medical providers, alleging, inter alia, claims of medical malpractice and negligence. The superior court granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding that the hearing justice (1) did not overlook genuine disputes as to material facts that would preclude summary judgment; (2) did not err in finding that the doctrine of res ipsa loquitur could not properly be applied to the facts of this case; and (3) did not err in granting summary judgment in light of what Defendant alleged was the “egregious conduct” of his former attorney. View "Laplante v. Rhode Island Hospital" on Justia Law

When Ferris Avenue Realty, LLC (Ferris) purchased twenty-two acres of property from Huhtamaki, Inc. (Huhtamaki), the parties executed an indemnity agreement providing that, upon the occurrence of certain conditions, Huhtamaki would reimburse Ferris for environmental cleanup costs. After hazardous substances were found on the property and Ferris incurred certain costs related to the cleanup of the substances, Ferris requested indemnification from Huhtamaki. Huhtamaki refused to indemnify Ferris. After a jury trial, judgment was entered in favor of Ferris. The Supreme Court affirmed, holding that the trial justice did not err in (1) finding that Ferris’s notice to Huhtamaki constituted sufficient “claim notice” pursuant to the terms of the indemnity agreement; (2) admitting certain testimony from Ferris’s expert witness; (3) admitting evidence relating to excavated soil samples where Ferris excavated the soil before Huhtamaki could test it; and (4) instructing the jury. Lastly, contrary to Huhtamaki’s argument, Ferris’s case was not built on an improper “pyramid of inferences.” View "Ferris Avenue Realty, LLC v. Huhtamaki, Inc." on Justia Law

Plaintiff applied to the Town Planning Board for the Town of Hopkinton for a preliminary plan approval of a minor subdivision. The Town Planner stated that he would certify the subdivision application as complete once Plaintiff submitted proof that it had paid certain outstanding personal property taxes. Plaintiff filed a complaint seeking a writ of mandamus to compel the Town Planner to certify its subdivision application as complete (the mandamus count) and amended its complaint to add a count seeking a declaration that the requirement for an applicants such as Plaintiff to pay “property taxes” refers only to real property taxes (the declaratory judgment count). The trial justice dismissed the mandamus count but for Plaintiff’s failure to exhaust its administrative remedies but summarily ruled that the declaratory judgment count survived. The trial justice subsequently denied, sua sponte, Plaintiff’s request for declaratory relief, concluding that Plaintiff had failed to exhaust its administrative remedies. The Supreme Court vacated the judgment and remanded, holding that the trial justice abused his discretion when he sua sponte invoked the administrative exhaustion doctrine in the course of denying Plaintiff declaratory relief where neither party had briefed or argued that doctrine. View "Bruce Brayman Builders, Inc. v. Lamphere" on Justia Law

In Huntley I, the Supreme Court determined that a judgment entered in the federal district court for the defendants, including the State and the Office of the Attorney General, against Plaintiff Dawn Huntley was entitled to preclusive effect. Undaunted by the opinion in Huntley I, Plaintiff argued that her state court action was still viable because individual defendants Mr. Goulart, Mr. Coyne, and Mr. Lynch, had not pled or otherwise defended the civil action. Plaintiff and her attorney (together, Appellants) obtained default judgment against Mr. Goulart and filed similar applications for entry of default against Mr. Coyne and Mr. Lynch. A justice of the superior court vacated the default entered against Mr. Goulart and sustained Mr. Coyne’s and Mr. Lynch’s objections to the pending applications for entry of default against them. The hearing justice then sanctioned Appellants, ruling that the applications for default had not been filed in good faith. The Supreme Judicial Court affirmed, holding (1) Huntley I was clearly applicable to the individual defendants and Appellants had not standing to challenge the individual defendants’ representation by the Office of the Attorney General; and (2) there was no abuse of discretion in the hearing justice’s sanction. View "Huntley v. State" on Justia Law

After a jury trial, Defendant was convicted of resisting arrest and disorderly conduct. Defendant appealed, asserting that her right to counsel guaranteed by both the federal and state Constitutions was violated when the trial justice allowed her to represent herself at trial without first determining whether she had made a knowing and intelligent waiver of her right to counsel. The Supreme Court affirmed, holding that, upon consideration of the totality of the circumstances at the time of Defendant’s waiver, the record established Defendant’s voluntary, knowing, and intelligent waiver of her right to counsel. View "State v. Cruz" on Justia Law

Gabrielle Mee passed away in 2008. Plaintiff, Gabrielle's niece, filed three separate cases in the superior court, alleging (1) Gabrielle’s will was executed through undue influence, fraud, and mistake in the inducement; (2) Gabrielle was unduly influenced and fraudulently induced into giving $60 million in lifetime gifts to the Legion of Christ North America, Inc.; and (3) Bank of America, N.A. breached its fiduciary duties as the trustee of multiple trusts set up by Gabrielle and her late husband. The superior court granted summary judgment in favor of all Defendants on the grounds that Plaintiff lacked standing to bring the actions. The Supreme Court (1) affirmed the trial justice’s decision as to Plaintiff’s lack of standing, as Plaintiff was not “a person legally interested in” Gabrielle's estate; but (2) vacated the trial justice’s decision requiring Plaintiff to pay attorneys’ fees in order to amend her reasons for appeal of the probate court decision, the imposition of attorneys’ fees in this case did not comport to what is “right and equitable under the circumstances and the law.” View "Dauray v. Mee" on Justia Law

Plaintiffs were a certified class of approximately 14,000 policyholders of Beacon Mutual Insurance Company, a state-chartered workers’ compensation insurance provider. Plaintiffs filed suit against Beacon, alleging that they were denied money that should have been equitably distributed to all policyholders as dividends, among other claims. The superior court dismissed the complaint and entered judgment in favor of Beacon, concluding that Plaintiffs’ claims were derivative in nature and that Plaintiffs failed file suit in accordance with R.I. Gen. Laws 7-1.2-711(c) and Rule 23.1 of the Superior Court Rules of Civil Procedure. Plaintiffs appealed, arguing that their claims met the requirements of a direct, and not a derivative, action and were therefore not subject to the procedural requirements of section 7-1.2-711(c) and Rule 23.1. The Supreme Court affirmed, holding that Plaintiffs’ claims were derivative in nature, and therefore, Plaintiffs were required to comply with the procedural requirements set forth in section 7-1.2-711(c) and Rule 23.1 before they commenced suit. Because Plaintiffs failed to comply with these requirements, the district court’s dismissal of the suit was proper. View "Heritage Healthcare Servs., Inc. v. Beacon Mut. Ins. Co." on Justia Law

Plaintiff filed this negligence action against Daniel Stack and the Disabled American Veterans Department of Massachusetts, Inc. (collectively, Defendants) seeking damages for injuries he received in an automobile accident. During the proceedings, the superior court justice made three rulings disputed by Defendants: (1) a denial of Defendant’s motion to compel additional discovery from material fact witnesses; (2) a grant of Plaintiffs’ motion for a protective order limiting Defendants’ planned neuropsychological examination of Plaintiff; and (3) a revocation of the pro hac vice admission of defense counsel. The Supreme Court granted Defendants’ petition for the issuance of a writ of certiorari regarding these issues and denied the petition in part and granted it in part, holding that the hearing justice (1) did not err in denying the motion to compel; (2) erred by precluding Defendants’ expert to take a history during the neuropsychological examination of Plaintiff and erred by allowing Plaintiffs’ attorney to be present during the testing phase of the examination but correctly allowed a third-party non-attorney representative to be present; and (3) erred by revoking defense counsel’s pro hac vice admission. View "Plante v. Stack" on Justia Law

In 1996, the parties were granted a divorce. When the divorce became final, the parties’ jointly executed property settlement agreement, which, among other things, set forth the distribution of Defendant’s retirement benefits, was incorporated but not merged into the final judgment. In 2012, Plaintiff sought enforcement of the provision that set forth Defendant’s obligation to make payments to her from his pension. The family court entered judgment in favor of Plaintiff and ordered Defendant to pay Plaintiff attorney’s fees and costs incurred to enforce the agreement. The Supreme Court (1) affirmed the judgment of the family court as to the pension benefits and interest due Wife; but (2) remanded the issue of attorney’s fees, holding that because the hearing justice never calculated them, the issue must be remanded for the family court to address the basis for such an award and the calculation thereof. View "Maccarone v. Maccarone" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and other offenses. Defendant appealed, asserting, among other claims of error, that the trial justice erred by deciding to limit the extent to which Defendant was allowed to cross-examine a key police witness, the lead detective in the case. The Supreme Court agreed with Defendant and vacated his convictions, holding (1) the proffered evidence was relevant; (2) the witness’s testimony would not implicate the holding in State v. Harnois; and (3) R.I. R. Evid. 403 would not bar the witness’s testimony. Remanded for a new trial. View "State v. Arciliares" on Justia Law