Justia Rhode Island Supreme Court Opinion Summaries

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

Plaintiff, a member of a union, filed a complaint against Defendant, her former employer, alleging that during her employment she was subjected to a hostile work environment on account of her race and color and that she was wrongfully terminated. Defendant filed a motion to stay proceedings, arguing that the proper forum for resolution of Plaintiff’s claims was binding arbitration as required by the collective bargaining agreement (CBA) between the union and Defendant. A hearing justice granted Defendant’s motion to stay and ordered that the matter be resolved through arbitration. Plaintiff appealed, arguing that the hearing justice’s decision was in error because the CBA’s arbitration provision did not preclude her from asserting her statutorily created rights under the Rhode Island Civil Rights Act (RICRA) and Rhode Island Fair Employment Practices Act (FEPA) in a judicial forum. The Supreme Court vacated the order of the superior court, holding that the CBA’s general arbitration provision, which contained no specific reference to the state anti-discrimination statutes at issue, did not constitute a clear and unmistakable waiver of Plaintiff’s right to a judicial forum in which to litigate her claims arising under the RICRA and the FEPA. Remanded.View "Weeks v. 735 Putnam Pike Operations, LLC" on Justia Law

In 1992, Appellant was incarcerated while awaiting the disposition of an allegation of first-degree child molestation. In 1994, Appellant pled nolo contendere to one count of first-degree child molestation. Appellant was sentenced to twenty years incarceration with twelve years suspended and twelve years probation. In 1997, Appellant was released from the Adult Correctional Institutions (ACI). Appellant completed his period of parole in 1999. In 2010, Appellant filed a petition for a writ of habeas corpus and applied for postconviction relief, arguing that his probationary period should have commenced and ended fifteen months earlier because his credit for time served caused him to be released from prison that much sooner. The superior court denied relief, concluding that Appellant’s sentence began in 1994 and ran until 2014. The Supreme Court affirmed, holding that the hearing justice did not miscalculate the length of Appellant’s sentence.View "Rose v. State" on Justia Law