Justia Rhode Island Supreme Court Opinion Summaries

Plaintiff, who was injured while working as a deckhand on a commercial vessel, sued Defendant, Huntress, Inc., for maintenance and cure, negligence under the federal Jones Act, and breach of the warranty of seaworthiness. After a trial, Plaintiff prevailed on his claim for maintenance and cure but not on his remaining claims. The trial justice subsequently denied Defendant’s motion for a new trial with respect to the claim for maintenance and cure and granted Plaintiff’s motion for a new trial with respect to the claims for negligence and breach of the warranty of seaworthiness. The Supreme Court (1) vacated the trial justice’s denial of Defendant’s motion for a new trial with respect to the claim for maintenance and cure, holding that the trial justice gave an improper instruction to the jury regarding “unearned wages,” and the error resulted in prejudice to Defendant; and (2) vacated the trial justice’s grant of Plaintiff’s motion for a new trial on the claims of negligence under the Jones Act and breach of the warranty of seaworthiness, holding that the trial justice overlooked and misconceived testimony, resulting in a decision that was clearly wrong. View "King v. Huntress, Inc." on Justia Law

Defendant agreed to furnish labor, materials, equipment, and services for a pipe-replacement project at Brown University. Defendant entered into a sub-contract with Plaintiff in which Plaintiff agreed to install the pipe. After Plaintiff completed its portion of the project, Plaintiff filed breach of contract and quantum meruit claims against Defendant, alleging that Defendant failed to pay for some of the work that Plaintiff performed on the project. The superior court entered judgment in favor of Plaintiff on its quantum meruit claim. The Supreme Court affirmed, holding that the trial justice did not misapply the law, misconceive or overlook material evidence, or make factual findings that were clearly wrong in reaching its decision. View "Process Eng’rs & Constructors, Inc. v. DiGregorio, Inc." on Justia Law

This case involved an ongoing dispute between two commercial landowners, Plaintiff and Defendant, over the existence of a prescriptive easement used by delivery trucks to access a loading dock owned by Plaintiff. After Defendant ordered the installation of barriers along the southwestern boundary of an express easement, it was nearly impossible for delivery vehicles to directly access the loading dock. Plaintiff filed a complaint, claiming a prescriptive easement over Defendant’s lot. In his second decision, the trial justice denied Plaintiff’s claim for a prescriptive easement. The Supreme Court affirmed, holding that Plaintiff failed to meet its burden of proof on the element of hostility, and therefore, Plaintiff could not succeed on its claim. View "Butterfly Realty v. James Romanella & Sons, Inc." on Justia Law

After a jury trial, Defendant was convicted of two counts of assault with a dangerous weapon and one count of simple assault. On appeal, Defendant argued, among other things, that the prosecutor improperly vouched for the credibility of two witnesses during her closing argument. The Supreme Court affirmed the convictions, holding (1) the trial justice did not abuse his discretion by allowing the state to impeach Defendant’s credibility with his fourteen prior criminal convictions; and (2) although a portion of the prosecutor’s closing argument was akin to vouching, the trial justice did not err by refusing to pass the case. View "State v. Whitfield" on Justia Law

Plaintiff was seventeen years old when he and his friends entered certain property reputed to be haunted. As Plaintiff and his companies were attempting to exit the building, a bottle containing sulfuric acid broke and splashed some of its contents onto Plaintiff, severely burning Plaintiff. Plaintiff conceded that he was a trespasser but sued the State under the doctrine of attractive nuisance. After a jury-waived trial, the superior court entered judgment for the State. The Supreme Court affirmed, holding that the trial justice did not err in (1) finding that the attractive-nuisance doctrine did not apply under the circumstances of this case; and (2) not finding that the State shared some comparative fault for Plaintiff's injuries.View "Burton v. State" on Justia Law

Lawrence LaBonte, the owner of New England Development RI, LLC (N.E. Development), filed a petition seeking the reorganization and/or the dissolution of N.E. Development. American Steel Coatings, LLC (American Steel) filed a motion to approve secured claim attempting to recover the funds it alleged were owed pursuant to a loan agreement between the parties. The LLC’s permanent receiver and LaBonte objected to American’s motion, asserting that the loan agreement was void because the amount of interest to be charged violated the state’s usury laws. The superior court sustained the objections and voided as usurious the loan agreement. The Supreme Court affirmed, holding that the loan agreement in this case was usurious and, therefore, void. View "LaBonte v. New England Dev. R.I., LLC" on Justia Law

Plaintiff executed a promissory note to Dollar Mortgage Corporation (DMC) secured by a mortgage on Plaintiff's real property. The mortgage was held by Mortgage Electronic Registration Systems (MERS) as the mortgagee and nominee for DMC. Eventually, Deutsche Bank National Trust Company became the holder of Plaintiff's note as custodian for OneWest Bank. Later, MERS assigned Plaintiff's mortgage to the Federal National Mortgage Association (FNMA). AFter Plaintiff defaulted on his mortgage, FNMA purchased the property at a foreclosure sale. Plaintiff subsequently file this action seeking declaratory relief as to the validity of the foreclosure sale and the ownership of the property, an order quieting title to the property, and damages for negligent misrepresentation. The trial court granted summary judgment for Defendants, finding, among other things, that Plaintiff did not have standing to challenge the validity of the assignment of the mortgage because he was a stranger to the assignment. The Supreme Court vacated in part and affirmed in part the judgment of the superior court, holding (1) Plaintiff had standing to challenge the validity of the assignment of the mortgage; and (2) the superior court did not err in the remainder of its judgment. View "Mruk v. Mortgage Elec. Registration Sys., Inc." on Justia Law

After a jury trial, Defendant was found guilty of two counts of second-degree child molestation sexual assault. The Supreme Court affirmed the superior court’s judgment of conviction and its denial of Defendant’s motion for a new trial, holding (1) the trial justice did not abuse his discretion in denying Defendant’s motion to pass the case after the prosecutor engaged in an improper line of questioning to a witness, as any prejudice which may have resulted was cured by the trial justice’s instruction to the jury; and (2) the trial justice did not misconceive or overlook material testimony and did not otherwise commit clear error in denying Defendant’s motion for a new trial. View "State v. Hie" on Justia Law

In 1990, Applicant was convicted of one count of first-degree sexual assault. In 2001, Applicant filed a pro se application for postconviction relief, alleging ineffective assistance of counsel and trial error. In 2005, the hearing justice denied the application. The Supreme Court affirmed, holding that the hearing justice properly did not commit clear error or misconceive material evidence in rendering his decision, as (1) Applicant’s claims relating to alleged errors committed by the trial justice were barred by the doctrine of res judicata; and (2) Applicant failed to show to his trial counsel’s representation fell below an objective standard of reasonableness. View "Lamoureux v. State" on Justia Law

Quest Diagnostics, LLC was an independent contractor for Brown University under an agreement that obligated both parties to name the other party as an additional insured under their general liability policies. In 2006, Pauline Hall, a student at Brown University, sought treatment at the university’s health services clinic. A rapid strep test, to be performed by Quest, was ordered. The test, however, was not performed promptly, and the results were not returned to the health clinic. Hall was subsequently diagnosed with toxic shock syndrome, which resulted in permanent injuries. Hall filed suit against Brown and Quest, and Brown filed a cross-claim against Quest. Hall settled her claims with Brown and its insurers, Pinnacle Consortium of Higher Education and Genesis Insurance Company, but the cross-claim was not resolved. Quest subsequently sought a declaratory judgment that it was entitled to a defense from Pinnacle and indemnification from Pinnacle and Genesis. The superior court granted summary judgment in favor of Pinnacle and Genesis. The Supreme Court affirmed, holding that, under the facts of this case, Quest was not entitled to defense and indemnification from either insurer. View "Quest Diagnostics, LLC v. Pinnacle Consortium of Higher Educ." on Justia Law