Justia Rhode Island Supreme Court Opinion Summaries

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

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