Justia Rhode Island Supreme Court Opinion Summaries

After an automobile accident that occurred between Camella Martin and Michael Coyne, Camella suffered a number of injuries. Camella died two years after the accident. Dennis Martin, as executor of the estate of Camella, filed this negligence action against Coyne. After a jury trial, judgment was entered for Defendant. The Supreme Court affirmed, holding (1) the trial justice did not err in granting Defendant's motion in limine to exclude a document from being submitted as evidence because the document was inadmissible hearsay; and (2) the trial justice did not err in denying Plaintiff's motion for judgment as a matter of law or, in the alternative, for a new trial, as the evidence supported the jury's verdict. View "Martin v. Lawrence" on Justia Law

After a jury trial, Defendant was convicted of assault with a dangerous weapon, carrying a pistol without a license, and using a firearm while committing a crime of violence. Defendant filed a motion for a new trial, arguing that the trial justice erred by accepting certain testimony. The trial justice denied Defendant's motion. Defendant appealed, contending that the trial justice overlooked and misconceived material evidence when denying his motion for a new trial. The Supreme Court affirmed, holding that the trial justice articulated adequate grounds for denying Defendant's motion and did not overlook or misconceive material evidence when making his decision.View "State v. Baker" on Justia Law

In 1990, Defendant pled nolo contendere to twenty-six offenses, including arson and a number of robberies. Defendant was sentenced to forty years' incarceration with twenty-eight years suspended, with probation, on the one arson and eight robbery charges. In 2011, a probation violation hearing was held based upon allegations of sexual assault. Thirteen witnesses testified during the hearing regarding the allegations. The superior court subsequently found Defendant to be in violation of the terms of his probation and sentenced him to serve the previously imposed suspended sentences. The Supreme Court affirmed, holding that the hearing justice's credibility findings were not arbitrary or capricious.View "State v. Raso" on Justia Law

Defendant was charged with several crimes in connection with a drive-by shooting. After a jury trial, Defendant was convicted of carrying a firearm in a motor vehicle without a license and attempting to elude a police officer. Defendant filed a motion for a new trial with respect to both convictions. The trial justice granted the motion on the charge of attempting to elude a police officer but denied the motion with respect to the firearm charge. The Supreme Court affirmed the superior court’s judgment of conviction, holding that the trial justice did not err in denying Defendant’s motion for a new trial with respect to the charge of carrying a firearm in a motor vehicle without a license. View "State v. Nabe" on Justia Law

Plaintiff, the former wife of Defendant, filed a complaint seeking protection from abuse from Defendant. A magistrate of the family court entered a temporary order restraining and enjoining Defendant from contacting Plaintiff. The chief judge of the family court affirmed the magistrate’s order. The Supreme Court affirmed, holding (1) Defendant’s conduct was of the type that the General Assembly mandated could be the predicate for the issuance of a protective order; and (2) the magistrate did not exceed her authority in issuing a civil restraining order after determining that the restraining order was necessary to protect Plaintiff from Defendant’s harassment. View "Cavanaugh v. Cavanaugh" on Justia Law

Plaintiff, a UPS driver, was delivering a package to the home of Defendants when he was bitten on his arm and leg by one of Defendants’ dogs. Plaintiff filed an action against Defendants, alleging that he was injured as a result of Defendants’ negligence in failing to secure their dogs. The superior court granted summary judgment for Defendants, concluding that there was no genuine issue of material fact about whether Defendants knew of the dog’s vicious propensity. The Supreme Court vacated the judgment of the superior court, holding that material issues of fact existed that could permit a fact-finder that the dog did have a vicious propensity and that Defendants knew of it. View "Coogan v. Nelson" on Justia Law

After a jury trial, Defendant was found guilty of six counts of first-degree sexual assault and four counts of second-degree sexual assault stemming from his unlawful conduct with his girlfriend’s daughter. Defendant was sentenced to fifty years, with twenty-five years suspended, with probation. The Supreme Court affirmed, holding that the trial justice (1) did not err in admitting evidence concerning prior acts of misconduct committed by Defendant against the complainant, including “play fighting” evidence and corporal punishment evidence; (2) did not err by allowing an examining physician to testify to statements made by the complainant during the course of her treatment; and (3) did not err by denying Defendant’s motion for a new trial. View "State v. Watkins" on Justia Law

Plaintiff, Rose Nulman Park Foundation, owned real property that was used as a park. In 2011, Defendants, Robert Lamoureux and Four Twenty Corporation, completed construction on a $1.8 million home. A prospective buyer of the home had a survey conducted which revealed that the building was entirely located on Plaintiff’s property. Plaintiff filed suit against Defendants, asserting that the structure constituted a continuing trespass on the property and requesting a mandatory injunction ordering Defendants to remove the structure. The trial justice concluded that a 13,000 square foot intrusion, amounting to six percent of the Nulman property, was not a de minimus encroachment and, accordingly, ordered Defendants to remove the structure. The Supreme Court affirmed after concluding that it would be unjust to order the transfer of title to a portion of the Nulman property to Defendants or to award only money damages, holding that injunctive relief was the appropriate remedy in this case. View "Rose Nulman Park Found. v. Four Twenty Corp." on Justia Law

Defendant was charged with several counts of first-degree child molestation and second-degree child molestation stemming from Defendant's unlawful conduct with the niece of his girlfriend. The case proceeded to trial. During the redirect-examination of the complaining witness, the trial justice admitted into evidence some nonspecific testimony about previous, uncharged acts of sexual misconduct. The jury eventually convicted Defendant of two counts of first-degree child molestation and three counts of second-degree child molestation. Defendant appealed, challenging the trial justice’s admission of the testimony about prior bad acts. The Supreme Court affirmed, holding that the trial justice did not abuse her discretion when she permitted the complaining witness to testify about other nonspecific evidence of prior bad acts. View "State v. Acevedo" on Justia Law

The Rhode Island Joint Reinsurance Association brought an interpleader action against multiple defendants for the purpose of determining the proper disposition of insurance proceeds. Bank of America, N.A. (BANA), one of the defendants, moved for summary judgment on the interpleader claim and against defendant Genoveva Santana-Sosa’s cross-claim. The superior court granted summary judgment for BANA, concluding that BANA was entitled to the entire amount of the insurance proceeds and that Santana-Sosa was entitled to none of the disputed funds. The Supreme Court affirmed, holding that BANA was entitled to judgment as a matter of law. View "R.I. Joint Reinsurance Ass’n v. Santana-Sosa" on Justia Law