Justia Rhode Island Supreme Court Opinion Summaries

Following Defendant's assault on Plaintiff, Plaintiff sued Defendant for negligence, assault, and battery. After deliberation, the jury returned a verdict awarding Plaintiff $1.75 million in damages plus interest. The superior court granted Defendant’s motion for a remittitur and awarded Plaintiff damages of $925,000. Defendant appealed, arguing that, despite the remittitur, the final ruling rendered in favor of Plaintiff was excessive and punitive in nature. The Supreme Court affirmed the judgment of the superior court, holding that the trial justice did not misconceive or overlook material evidence and acted properly in granting Defendant’s motion and reducing the damages to $925,000. View "Hough v. McKiernan" on Justia Law

Decedent died less than two weeks after executing her last will and testament. The will bequeathed nothing to Decedent’s heirs-at-law. After a lengthy contest that challenged the validity of the will, the will was admitted to probate. The contestant in this case, along with the remaining heirs-at-law, appealed, arguing that Decedent lacked testamentary capacity at the time she executed the instrument and that the will was procured by undue influence. The superior court concluded that the contestant and remaining heirs-at-law failed to prove their claims. The Supreme Court affirmed, holding that the trial justice did not err by (1) failing to state specifically that the will was executed in compliance with statutory requirements; (2) concluding that the will was not the product of undue influence; (3) finding that Decedent possessed the requisite testamentary capacity to execute the will; and (4) making factual findings and conclusions of law. View "In re Estate of Picillo" on Justia Law

Scott Cohen’s vehicle collided with the rear of Antonio Soares’s stopped vehicle because Cohen's vision was temporarily impaired by the glare from the morning sun. Cohen waved to Kris Ellinwood, a police officer who was directing traffic at the time, to approach the scene. Cohen assured Ellinwood that everyone was unharmed but did not mention the sun glare. Ellinwood was writing down information in between Cohen's and Soares's vehicles when Andrew Thornley, who did not see Cohen’s vehicle due to solar glare, struck the rear of Cohen’s vehicle, causing Ellinwood to be pinned between Cohen’s and Soares’s vehicles and crushing his legs. Ellinwood filed an action against Cohen, alleging that Cohen negligently failed to warn him of the solar glare, a dangerous condition. The superior court granted Cohen’s motion for summary judgment, concluding that the public safety officer’s rule shielded Cohen from liability. The Supreme Court affirmed, holding that the public-safety officer’s rule barred Ellinwood’s negligence claim as a matter of law because Ellinwood could have reasonably foreseen that he could be struck and injured by another vehicle while coming to Cohen’s assistance.View "Ellinwood v. Cohen" on Justia Law

In the town of Tiverton, two police officers from the Little Compton police department had a discussion with Defendant about a motor-vehicle accident that occurred in Little Compton. The officers then transported Defendant in a police cruiser back to the scene of the accident, where they administered field-sobriety tests, which Defendant failed. Defendant was subsequently charged with driving under the influence of liquor or drugs, among other offenses. Defendant filed a motion to dismiss due to an unlawful arrest, arguing that the officers lacked the authority to arrest him in Tiverton. The trial judge concluded that the arrest was unlawful and dismissed the case. The Supreme Court quashed the judgment of the district court, holding that Defendant was not arrested by the Little Compton police while they were in Tiverton, and therefore, the trial judge erred when she granted Defendant’s motion to dismiss. Remanded.View "State ex rel. Town of Little Compton v. Simmons" on Justia Law

Plaintiff, a state employee, filed an action against the State Department of Mental Health, Retardation and Hospitals (MHRH) alleging that MRH violated the Rhode Island Whistleblowers’ Protection Act (WPA) when it placed him on administrative leave with pay and required that he undergo an independent medical examination (IME). The superior court found in favor of Plaintiff. The Supreme Court vacated the judgment of the superior court, holding that the decision of the MHRH to place Plaintiff on paid administrative leave with the requirement that he undergo an IME was not an adverse employment action, and therefore, as a matter of law, the MHRH did not “discharge, threaten, or otherwise discriminate” against Plaintiff in violation of the WPA.View "Russo v. State, Dep’t of Mental Health, Retardation and Hosps." on Justia Law

After a jury trial, Defendant was convicted of second-degree robbery and sentenced to a total of thirty years imprisonment. The Supreme Court affirmed, holding (1) the trial justice did not err in denying Defendant’s motion to sever the count charging a codefendant with carrying a handgun without a license, as Defendant did not show he suffered prejudice from the joinder of the charge to such a degree that he was denied a fair trial; and (2) the remainder of Defendant’s allegations of trial error were not preserved for appellate review.View "State v. Gadson" on Justia Law

In 1997, Defendants formed a Vermont corporation called Green Mountain Park, Inc. to reconstruct, revive, and operate a defunct horseracing facility in the Town of Pownal, Vermont. Plaintiff agreed to invest $350,000 in the enterprise. Plaintiff subsequently became a member of the board of directors along with Defendants. A few years later, the project was abandoned due to issues surrounding Green Mountain’s ability to obtain a racetrack license. Defendants filed a complaint against Plaintiff in 2002, and Plaintiff counterclaimed for breach of fiduciary duty, fraud, and breach of contract. Defendants’ complaint was subsequently dismissed, and the case proceeded to trial on Plaintiff’s counterclaims. After a bench trial, the superior court entered judgment for Defendants on all counts. The Supreme Court affirmed, holding that the trial justice did not err in his factual findings and conclusions of law.View "Wilby v. Savoie" on Justia Law

The Moorland Farm Condominium consisted of thirty-three units in ten buildings. When the Moorland Farm Condominium Association became aware that certain outdoor decks in the condominium development were in need of repair, it issued a series of special assessments to pay for the repairs. Plaintiffs, owners of the condominium units that were not benefiting from the improvements, sued the association, contending that the assessments were illegal because the decks were not common areas, but rather, were part of individual units. The trial justice held that the assessments were illegal. The association appealed, arguing that the trial justice erred by advancing to trial in the absence of all indispensable parties, in particular, the unit owners who received the benefit of the association’s assessment for deck repairs but who would bear the financial burden of the reallocated costs as set forth in the judgment. The Supreme Court vacated the judgment, holding that the failure to join indispensable parties in this case was fatal and that the judgment was null and void.View "Burns v. Moorland Farm Condo. Ass’n" on Justia Law

Defendant hired Plaintiff twice when Plaintiff was sixty-seven years old for brief periods of employment. When Plaintiff was sixty-eight, Defendant rehired her as a titles and registrations clerk. When Plaintiff was seventy-two years old, Defendant terminated her employment. Plaintiff filed an action against Defendant for unlawful age and disability discrimination in violation of the Fair Employment Practices Act. The superior court granted summary judgment for Defendant on both employment discrimination claims. The Supreme Court affirmed, holding that the trial justice did not err (1) in finding that Defendant met its burden of producing a legitimate nondiscriminatory reason for Plaintiff’s dismissal, and (2) in holding that Plaintiff failed to demonstrate that those reasons were merely pretextual.View "Bucci v. Hurd Buick Pontiac GMC Truck, LLC " on Justia Law

After Plaintiff’s car was struck from behind by a car operated by Defendant, Plaintiff began experiencing pain in her back and legs, which led to two surgical procedures on her spine. Plaintiff filed a negligence suit against Defendants seeking damages. The jury returned a verdict for Plaintiff and awarded her damages in the amount of $193,584. Plaintiff filed a motion for a new trial and/or additur, contending that the verdict was against the weight of the evidence and that the jury’s damages award failed adequately to compensate her for her injuries so as to shock the conscience. The superior court granted an additur of $428, 416 to the jury award and, if Defendants rejected the additur, granted Plaintiff’s motion for a new trial on the limited issue of damages. Defendants rejected the additur. The Supreme Court affirmed the trial justice’s grant of Plaintiff’s motion for a new trial on the issue of damages, holding that the trial justice (1) adequately set forth sufficient record evidence to support his independent judgment; and (2) was not clearly wrong in determining that the jury’s award of damages was inadequate.View "Rose v. Cariello" on Justia Law