Justia Rhode Island Supreme Court Opinion Summaries

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

One evening, Shawn McKiernan drove by Kevin Hough several times in an automobile owned by Rita Bower and taunted Hough as he drove past. McKiernan subsequently exited the insured vehicle and punched Hough, who was knocked to the pavement. Hough suffered a serious head injury as a result of the assault and battery. Hough filed a negligence complaint against Bower as the vehicle owner, alleging liability under the provisions of R.I. Gen. Laws 31-33-6, which imputes vicarious liability upon the owner of a vehicle for its consensual use or operation. Due to the subsequent death of Bower, Quincy Mutual Fire Insurance Company, the insurer of the vehicle, was substituted as a party defendant. The trial justice granted judgment as a matter of law in favor of Quincy. The Supreme Court affirmed, holding that Plaintiff failed to establish the causal relationship between the use of the vehicle and the injuries sustained by Plaintiff required to impute liability under section 31-33-6. View "Hough v. McKiernan" on Justia Law

Plaintiff obtained a mortgage loan from Equity One, Inc. As security for the note, Plaintiff executed a mortgage on the property in favor of Mortgage Electronic Registration Systems (MERS). The note was twice transferred, eventually landing in the possession of Deutsche Bank, National Trust Company. Litton Loan Servicing, L.P. was retained to service the loan. Meanwhile, MERS, as nominee for Equity One, assigned its interest in the mortgage to Deutsche Bank. After Litton and Deutsche Bank initiated foreclosure proceedings, Plaintiff filed an action alleging that the assignment from MERS to Deutsche Bank was invalid for lack of authority. When Plaintiff sought to depose a MERS designee, MERS filed a motion for a protective order, arguing that Plaintiff lacked standing to challenge the assignment. The superior court denied the motion. MERS filed a petition for a writ of certiorari. Litton and Deutsche Bank then moved for summary judgment, which the hearing justice granted. The Supreme Court (1) quashed the order denying MERS’ motion for a protective order, holding that Plaintiff lacked standing to challenge the assignment in question; and (2) affirmed the grant of summary judgment for Litton and Deutsche Bank, holding that MERS had the authority to assign the mortgage. View "Genao v. Litton Loan Servicing, L.P." on Justia Law

Plaintiff was a patron at a bar on Defendant’s premises when he was involved in a fight first inside Defendant’s premises and then in Defendant’s parking lot. Plaintiff sustained serious injuries. Plaintiff subsequently filed a negligence complaint against Defendant. After a trial, the jury returned a verdict finding both parties negligent, attributing twenty percent of the negligence to Plaintiff, and awarding a total of $543,433 to Plaintiff. Defendant filed a motion for a new trial and/or remittitur, which the trial justice denied. The Supreme Court affirmed, holding that the trial justice did not overlook or misconceive material evidence in denying Defendant’s motion for a new trial and alternative motion for a remittitur. View "Bitgood v. Gordon Greene Post Number 27 of the Am. Legion" on Justia Law

These consolidated appeals concerned a highly contested labor dispute between the Town of North Kingstown and the North Kingstown Firefighters, Local 1651, International Association of Firefighters, AFL-CIO (“union”). At the heart of the litigation was the town’s unilateral implementation of a three-platoon structure and the effects of that reorganization, including a change to a twenty-four hours on, forty-eight hours off schedule. The superior court issued various declaratory and injunctive relief. The Supreme Court affirmed in part, and reversed and remanded in part, holding (1) the town’s actions in implementing its decision to change to a three-platoon structure were lawful under the circumstances; but (2) provided that the union complies with the requirements of the Firefighters Arbitration Act and makes timely requests, the town must bargain regarding the effects of its decision to implement the three-platoon structure. View "Town of North Kingstown v. Int’l Ass’n of Firefighters, Local 1651" on Justia Law

Imperial Capital Bank granted a loan to Main and West, LLC in the sum of $607,500. Main and West signed a promissory note as security for the loan, and two individuals personally guaranteed the loan. City National Bank (Plaintiff) acquired the loan after Imperial dissolved. When Main and West defaulted on the note, Plaintiff filed suit seeking full payment of the obligations of Defendants - Main and West and the guarantors. The trial justice granted summary judgment for Plaintiff. Defendants appealed, arguing that the trial justice erred in granting summary judgment because he considered an exhibit that was viewed in camera without having afforded defense counsel an opportunity to review it. The Supreme Court vacated the summary judgment and remanded, holding that the trial justice inappropriately reviewed and relied on a document not shown to defense counsel in granting summary judgment. View "City Nat’l Bank v. Main & West, LLC" on Justia Law