Justia Rhode Island Supreme Court Opinion Summaries

Respondents, two firefighters, objected to orders from their superiors that they serve as part of the crew of a fire engine in the 2001 Pride Parade. Notwithstanding their objections, Respondents were ordered to cary out the task assigned, and they reluctantly took part in the parade. Thereafter, Respondents sued Petitioners, the former Providence Mayor and former Chief of the Providence Fire Department, as well as the City of Providence, on a variety of state and federal claims. Petitioners moved for summary judgment on two of those claims, invoking the doctrine of qualified immunity from suit. The superior court denied the motion for summary judgment. The Supreme Court quashed the judgment of the superior court, holding that, in view of the facts of this case, it was not necessary to invoke the doctrine of qualified immunity because no constitutional violation occurred. Remanded with instructions that Petitioners’ motion for summary judgment be granted. View "Fabrizio v. City of Providence" on Justia Law

AIDG Properties, LLC, a real-estate holding company managed by Anjan Dutta-Gupta, purchased property. AIDG obtained loans from BankNewport (Defendant) to finance the purchase and to perform improvements. Dutta-Gupta personally guaranteed the loans. Emond Plumbing & Heating, Inc. and Tecta America New England, LLC (collectively, Plaintiffs) served as subcontractors on the project. Plaintiffs substantially completed the renovations, and BankNewport deposited the loan proceeds into AIDG’s account. After Dutta-Gupta was arrested, Defendant declared Dutta-Gupta to be in default and accelerated the loans. Defendant then set off the deposit it made previously by reversing it. As a result, AIDG was unable to pay Plaintiffs for the work they had performed. Defendant, who was granted possession of the property, later foreclosed. Plaintiffs filed a complaint seeking to recover compensation for their work under the theory of unjust enrichment. The superior court granted summary judgment for Defendant. The Supreme Court affirmed, holding that due to the absence of a relationship between Plaintiffs and Defendant and the lack of any allegation that Defendant engaged in any type of misconduct or fraud, Defendant’s retention of the property, including the improvements, was not inequitable under the Court’s jurisprudence on unjust enrichment. View "Emond Plumbing & Heating, Inc. v. BankNewport" on Justia Law

Plaintiff fell while walking on the sidewalk outside Provide Place Mall. Plaintiff filed a negligence complaint against the City of Providence, as well as Old Navy, LLC and Joe’s American Bar and Grill, which leased the individual space on the ground floor in close proximity to the fall. A hearing justice granted summary judgment for Joe’s and Old Navy on the ground that the occupant of land may not be held liable for injuries sustained by pedestrians walking on the sidewalk located in front of the occupants’ businesses. The Supreme Court affirmed, holding that there was no basis to conclude that Defendants could have caused the defect in the sidewalk that caused Plaintiff’s fall, and Plaintiff’s claim that genuine issues of material fact existed as to control, use, and possession failed. View "Maguire v. City of Providence" on Justia Law

Plaintiff, an architectural firm, signed an agreement with the Rhode Island Department of Human Services (DHS) to provide architectural and engineering services for renovations at a state-owned property. A Blanket Purchase Agreement (BPA) referencing the agreement stated that the compensation was not to exceed a certain amount. When Plaintiff requested additional compensation without success, Plaintiff filed a complaint in the superior court seeking relief. The matter was held in abeyance while a statutory arbitration procedure was underway. The arbitrator concluded that, while Plaintiff rendered additional services to DHS, the additional work was not authorized under the BPA, and therefore, Plaintiff was not entitled to additional compensation. Plaintiff then filed a petition to compel arbitration in the superior court against DHS. The trial justice denied relief, concluding that Plaintiff’s claims were barred by the doctrine of res judicata. The Supreme Court affirmed, holding that the doctrine of res judicata barred Plaintiff’s claims. View "Torrado Architects v. R.I. Dep’t of Human Servs." on Justia Law

After a jury trial, Defendant was convicted of one count of assault with a dangerous weapon and one count of simple assault and battery. Defendant was sentenced to fifteen years imprisonment, with five years to serve and ten years suspended. The Supreme Court affirmed, holding (1) the trial justice did not err by denying Defendant’s motions for judgment of acquittal and new trial, as the evidence was sufficient to support the verdict; (2) the trial justice did not err by not allowing Defendant to cross-examine the complaining witness concerning custody issues involving her sons; and (3) Defendant’s challenge to his sentence was not properly before the Court for review. View "State v. Storey" on Justia Law

R. Suzanne Smith hired Michael Ead to construct an addition onto her home. After receiving notice that the construction was in violation of the local zoning ordinance, Smith ceased construction and decided to sell the property. Raymond Wells and his wife offered to purchase the property on the condition that they remove the addition. Wells enlisted Plaintiff to help demolish the newly constructed addition. While working at the site, Plaintiff fell from the roof and was injured. Plaintiff sued Smith and Ead (together, Defendants), alleging negligence, among other claims. The trial justice granted summary judgment for Defendants. The Supreme Court affirmed, holding that the trial justice did not err in granting summary judgment as to (1) Plaintiff’s claim of negligent hiring against Smith, as Smith had no duty to ensure that what Ead built would be safe for a demolition; and (2) Plaintiff’s claims of negligent design, construction, and inspection against Ead, as Ead did not have a legal duty to make the roof safe for dismantling. View "Wells v. Smith" on Justia Law

Plaintiff allegedly suffered from chronic headaches, which she treated with the medication Percocet, while enrolled in the nursing program at the Community College of Rhode Island (CCRI). Plaintiff filed a disability discrimination action against CCRI, the Board of Governors for Higher Education, and two individuals (collectively, Defendants), alleging that she had been dropped from the nursing program at CCRI because of her disability. The jury reached a verdict for Defendants. The Supreme Court affirmed, holding that the trial justice did not err by (1) admitting into evidence a medical report prepared by a neurologist who treated Plaintiff after she left the college; and (2) excusing a juror on the fourth day of trial due to concerns about his objectivity. View "Thornley v. Cmty. College of R.I." on Justia Law

Plaintiffs executed a promissory note in order to purchase certain real property. To secure payment obligations under the note, Plaintiffs executed a mortgage on the property. Mortgage Electronic Registration Systems, Inc. (MERS), as nominee for the original lender, assigned its interest in the mortgage to OneWest Bank, FSB (OneWest), which was then authorized to service the note for Federal National Mortgage Association (Fannie Mae). When Plaintiffs failed to make timely payments, OneWest initiated foreclosure proceedings. Plaintiffs filed an action against MERS and OneWest seeking a declaration that the assignment from MERS to OneWest was invalid and to quiet title to the property. OneWest eventually held a sale, and the property was sold to Fannie Mae. The hearing justice granted summary judgment for Defendants, concluding (1) MERS validly assigned its interest in the mortgage to OneWest, and therefore, OneWest had the statutory power of sale; (2) Plaintiffs defaulted under the terms of the note; and (3) Fannie Mae, as the buyer at the foreclosure sale, held the record title to the property. The Supreme Court affirmed, holding that the hearing justice did not err in determining that no genuine issue of material fact existed such that granting summary judgment in favor of Defendants was appropriate. View "Breggia v. Mortgage Elec. Registration Sys., Inc." on Justia Law

Pawtucket Redevelopment Agency (PRA) filed a complaint against Patricia Brown alleging that the PRA had entered into an agreement with Defendant to loan her $100,000 toward the purchase and maintenance of a classic diner and that Defendant had breached the agreement by defaulting on repayment of the advance and refusing to repay the loan. Defendant filed an answer and a counterclaim. A jury returned a verdict in favor of the PRA on its book account claim and also rendered a verdict in favor of Defendant on her negligent misrepresentation counterclaim. The PRA subsequently filed a renewed motion for judgment as a matter of law and a motion for a new trial on Defendant's counterclaim. The trial justice denied the motion for judgment as a matter of law but granted the motion for a new trial, concluding that the damages awarded to Defendant was against the fair preponderance of the evidence. The Supreme Court affirmed, holding (1) Plaintiff did not timely appeal the denial of its motion for judgment as a matter of law; and (2) the trial justice did not err in granting the PRA’s motion for a new trial and to set aside the jury verdict on Defendant’s counterclaim. View "Pawtucket Redevelopment Agency v. Brown" on Justia Law

After a second jury trial, Defendant was convicted of one count of felony assault, one count of simple assault, and one count of first-degree child abuse. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice (1) did not abuse his discretion by denying Defendant’s motion for a continuance in order for the defense to investigate genetic-testing results that were provided to the defense during jury selection in the second trial; and (2) did not err or violate Defendant’s right to present a defense by prohibiting Defendant’s father from testifying in Defendant’s case-in-chief. View "State v. Verry" on Justia Law