Justia Rhode Island Supreme Court Opinion Summaries
D’Alessio v. State
In 2002, Applicant was convicted for the second-degree murder of his infant daughter. In 2007, Applicant filed an application for postconviction relief, alleging that newly discovered evidence required a new trial. At a hearing before a justice of the superior court, Applicant presented the testimony of Dr. Richard T. Callery, who, while he was employed with Rhode Island’s Office of State Medical Examiners, had reviewed the victim’s file. The hearing justice denied the application for postconviction relief, concluding that the newly discovered evidence was not material and would not change the verdict at trial. The Supreme Court affirmed, holding that the testimony of Dr. Callery did not warrant postconviction relief. View "D’Alessio v. State" on Justia Law
Posted in:
Criminal Law
State v. Wray
In January 2006, Defendant was charged with two counts of first-degree robbery and presented as a probation violator. In April 2006, Defendant was adjudicated a probation violator and began serving his previously suspended sentences for drug-related charges. Defendant was found guilty on both counts and sentenced in April 2009. Three years later, Defendant filed a motion for credit for time served, arguing that his sentence in the robbery case should have been reduced by the number of days that he spent incarcerated between his arrest and his sentencing. The trial court denied the motion. The Supreme Court affirmed in part and vacated in part the order of the superior court, holding that, pursuant to R.I. Gen. Laws 12-19-2, Defendant was entitled to a credit for the time he spent incarcerated between January 2006 and April 2006. View "State v. Wray" on Justia Law
Posted in:
Criminal Law
State v. Miguel
Defendant pled guilty to second-degree murder and was sentenced to life imprisonment. This appeal concerned Defendant’s third attempt to challenge his plea and sentence with a motion to reduce or correct sentence pursuant to Rule 35 of the Superior Court Rules of Criminal Procedure. The trial justice denied the motion. Defendant appealed, arguing that his life sentence was illegal because he should have been convicted of manslaughter, which carries a maximum sentence of thirty years, and that the continued imposition of his purportedly illegal sentence constituted a violation of the Eighth Amendment to both the federal and the state Constitutions. The Supreme Court affirmed, holding that there was no error in the hearing justice’s decision to deny the Rule 35 motion and that Defendant’s constitutional arguments had no merit. View "State v. Miguel" on Justia Law
Berman v. Sitrin
Simcha Berman fell and was severely injured while descending a path that abuts the paved portion of The Cliff Walk, a major Newport tourist attraction that runs along Newport’s shoreline. Berman and his then-wife (together, Plaintiffs) sued the State and other defendants not related to this appeal. The jury found that the State was not negligent in inspecting, maintaining, and repairing the location where Berman fell. The Supreme Court affirmed, holding (1) judgment was correctly entered for the state; and (2) the trial court did not err in refusing to grant Plaintiffs’ motions for judgment as a matter of law, a new trial, and to vacate the judgment. View "Berman v. Sitrin" on Justia Law
Posted in:
Injury Law
State v. McKinnon-Conneally
Defendant pled nolo contendere to second degree robbery and was sentenced to a term of incarceration with eight and one-half years suspended, with probation. The state later filed a violation notice against Defendant for allegedly violating the terms of her probation. A hearing justice found that Defendant had violated the conditions of her probation by failing to keep the peace and maintain good behavior and imposed the previously suspended sentence. The Supreme Court affirmed, holding that the hearing justice did not abuse his discretion in executing the remaining eight and one-half years of Defendant’s previously suspended sentence. View "State v. McKinnon-Conneally" on Justia Law
Posted in:
Criminal Law
Raiche v. Scott
Plaintiff-construction company filed suit asserting that Defendant-homeowners breached the parties’ contract in which Plaintiff agreed to complete construction work on Defendants’ home. Further, Plaintiff alleged that Defendants were unjustly enriched in failing to pay the balance owed to Plaintiff. The trial justice awarded Plaintiff $55,455 in damages plus prejudgment interest on an offer of judgment that had been deposited in the Registry of the Superior Court. Defendants appealed the decision to award prejudgment interest, and Plaintiff cross-appealed the damages award. The Supreme Court dismissed the appeals of both parties and affirmed the judgment, holding that the trial justice was not clearly wrong in awarding statutory interest in the offer of judgment and in his conclusion that Plaintiff was entitled to $55,455. View "Raiche v. Scott" on Justia Law
Posted in:
Construction Law, Contracts
Fed. Nat’l Mortgage Ass’n v. Malinou
In 2003, the Supreme Court held that Seattle Savings Bank had the right to foreclose on certain property that Defendant inherited from his mother. In 2007, the Bank executed a quitclaim deed conveying the property to the Federal National Mortgage Association (Fannie Mae). Because Defendant refused to vacate the property, Fannie Mae filed a trespass and ejectment complaint. Defendant, in turn, argued that Fannie Mae was not entitled to possession of the property. The trial court awarded Fannie Mae possession of the property. The Supreme Court affirmed, holding that the superior court correctly found that Fannie Mae had the right to possess the property. View "Fed. Nat’l Mortgage Ass’n v. Malinou" on Justia Law
Posted in:
Banking, Real Estate & Property Law
Leone v. Mortgage Elec. Registration Sys.
A mortgage deed designated Desmond Leone as the mortgagor of his home and Mortgage Electronic Registration Systems (MERS) as the mortgagee, acting as nominee for the lender, Equity One, Inc. MERS later assigned its interest in the mortgage to Assets Recovery Center Investments, LLC (ARC). When Leone failed to make timely payments to the lender, ARC, which Equity One had authorized to act on its behalf, initiated foreclosure proceedings. Leone subsequently filed a complaint seeking a declaration that the assignment from MERS to ARC was invalid and also sought to quiet title to the property. A hearing justice granted summary judgment in favor of Defendants - MERS, Equity One, and ARC. The Supreme Court affirmed, holding that the hearing justice properly found that no genuine issues of material fact existed and that the matter was ripe for summary judgment in favor of Defendants. View "Leone v. Mortgage Elec. Registration Sys." on Justia Law
Posted in:
Banking, Real Estate & Property Law
Hough v. McKiernan
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
Posted in:
Injury Law
In re Estate of Picillo
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
Posted in:
Trusts & Estates