Justia Rhode Island Supreme Court Opinion Summaries

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

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