Justia Rhode Island Supreme Court Opinion Summaries

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

Plaintiffs, Nicholas Long and Julianne Ricci, purchased Dell computers in late 2000. In 2003, Plaintiffs filed this putative class action lawsuit alleging that Dell violated the Deceptive Trade Practices Act (DPTA) and was negligent in charging Plaintiffs sales tax on nontaxable services purchased in conjunction with the computers. The superior court granted summary judgment in favor of Dell. The case remained pending for more than ten years. Here, the Supreme Court (1) affirmed the grant of summary judgment on the negligence count and on the request for injunctive relief by Long; (2) vacated the grant of summary judgment on the DTPA count by Ricci; and (3) affirmed the superior court’s grant of Plaintiffs’ motion to strike the tax administrator’s affirmative defenses. Remanded. View "Long v. Dell, Inc." on Justia Law

In 2007, the Department of Children, Youth and Families (DCYF) filed petitions to terminate Mother’s and Father’s parental rights to their two sons. The Family Court terminated the parents’ parental rights, but the Supreme Court vacated the decree. New case plans were subsequently developed for the parents, but when the parents showed no progress and continued their alcoholic lifestyle, the DCYF filed new petitions to terminate both parents’ rights. In 2013, the Family Court terminated Mother’s and Father’s parental rights to their children. The Supreme Court denied and dismissed the parents’ appeals and affirmed the decree of the Family Court, holding that the trial justice did not err in finding, by clear and convincing evidence, competent proof to support the termination of the parents’ parental rights to their children. View "In re Steven D. " on Justia Law

At the college graduation party of Defendants’ son, a guest brought his all-terrain vehicle (ATV) to the party. Plaintiffs’ daughter, Ashley, requested a ride and voluntarily mounted the ATV. The guest crashed the ATV outside the Defendants’ premises. Ashley suffered traumatic brain injuries and died nine days later. Plaintiffs filed an action against Defendants, alleging negligence and wrongful death. The superior court entered judgment in favor of Defendants, concluding that Defendants did not owe a duty of care to Ashley. The Supreme Court affirmed, holding that Defendants did not owe a duty of care to Ashley under the facts of this case. View "Phelps v. Hebert" on Justia Law

After Plaintiff agreed to lease a motor vehicle he learned that he had been charged separately for property tax on the leased vehicle and an additional seven percent sales tax paid on that amount. Plaintiff filed a claim for a refund in the amount of sales tax he had paid on the property tax. The Division of Taxation denied Plaintiff’s claim. Plaintiff filed an appeal to the district court. Contemporaneously, Plaintiff filed a complaint in the superior court, seeking various forms of relief and seeking to certify his complaint as a class action. The superior court granted Defendants’ motion to dismiss the complaint for lack of jurisdiction. The Supreme Court affirmed, holding that the superior court lacked subject matter jurisdiction because the district court has exclusive jurisdiction over “tax matters.” View "Barone v. State" on Justia Law

Defendant pled nolo contendere to three counts of second-degree child molestation. Before he was sentenced, Defendant filed a motion to withdraw his plea. The trial justice denied the motion and sentenced Defendant to three concurrent sentences of fifteen years at the Adult Correctional Institutions. Eighteen months after sentencing, Defendant filed a motion to vacate judgment and sentence, arguing that his plea to the criminal charges should be set aside because his attorney did not inform him that the attorney was undergoing personal struggles during his representation of Defendant. The Supreme Court affirmed, holding (1) Defendant's appeal was not properly before the court; and (2) even if Defendant's argument was properly made, the argument was without merit.View "State v. Castriotta" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree child molestation and one count of second-degree child molestation. The Supreme Court affirmed the convictions on direct appeal. Appellant subsequently filed an application for postconviction relief, arguing that his trial counsel provided ineffective assistance. The trial justice denied the application, concluding that Appellant failed to establish that his counsel’s performance was deficient. The Supreme Court affirmed, holding that the trial justice did not err in finding that trial counsel performed at a high level and in thus denying Appellant’s application for postconviction relief. View "Merida v. State" on Justia Law

In 1998, Applicant was convicted of first-degree murder and conspiracy to commit first-degree murder. Applicant later filed an application for postconviction relief on the basis of ineffective assistance of counsel. In connection with his application, Applicant filed a subpoena duces tecum seeking discovery of the mental health records of Appellant, who testified as an eyewitness in Applicant's murder trial. Appellant filed a motion to quash the subpoena. The superior court denied the motion. The Supreme Court vacated the order and remanded with directions to make further factual findings, holding that the trial justice erred in ordering the release of Appellant's health care records without first conducting the necessary statutory analysis.View "DePina v. State" on Justia Law

Two young men, Brendan O’Connell Roberti and Jason Goffe, were killed in a tragic automobile collision. Plaintiffs, the co-administrators of the estate of Roberti, sued William Walmsley, who was driving the vehicle that collided with the vehicle in which Roberti was a passenger when he was killed. A jury found that Walmsley was negligent and that his negligence was a proximate cause of Roberti’s death. The trial justice, however, granted Walmsley’s motion for judgment as a matter of law, concluding that there was no evidence establishing that Defendant’s operation of his vehicle was a proximate cause of the collision. The Supreme Court vacated the judgment of the superior court granting Defendant’s motion for judgment as a matter of law, holding that a reasonable jury could assign liability to Walmsley. View "O’Connell v. Walmsley" on Justia Law

After Plaintiff filed a complaint for divorce from Dean Miller, Plaintiff and Dean executed a property settlement agreement providing that Dean would maintain life insurance for the benefit of the parties' four minor children until they reached the age of majority. Dean subsequently executed a service request form listing his children as the beneficiaries of his life insurance policy and instructing that beneficial interests be paid to and managed by Kristin Saunders as custodial trustee for the benefit of his minor children. After Dean died, funds from his life insurance policy were distributed to Saunders. Plaintiff filed a complaint seeking declaratory and injunctive relief asking the superior court to declare that Dean's four children were the sole beneficiaries of his life insurance policy. The court granted Defendants' motion for summary judgment, finding that Dean created a valid custodial trust pursuant to the Rhode Island Uniform Custodial Trust Act (RIUCTA) and that the trust was not inconsistent with Dean's obligations under the property settlement agreement. The Supreme Court affirmed, holding (1) Dean created a custodial trust pursuant to RIUCTA; and (2) Dean did not violate the property settlement agreement by designating Saunders as custodial trustee on the service request form.View "Miller v. Saunders" on Justia Law