Justia Rhode Island Supreme Court Opinion Summaries

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

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

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

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

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

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

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

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