Justia Rhode Island Supreme Court Opinion Summaries

Plaintiff signed an adjustable-rate note evidencing a loan from Bank of America and executed a mortgage on property that secured the loan. Bank of America was designated as the Lender and the mortgagee. After Plaintiff defaulted on his loan, a foreclosure auction was held at which Celtic Roman Group placed a successful bid. Before Celtic could close on the property, Plaintiff filed a notice of lis pendens in the land evidence records. Plaintiff subsequently filed a complaint challenging Bank of America’s authority to foreclose on the property. The superior court granted summary judgment for Defendants. The Supreme Court affirmed, holding (1) there was no genuine issue of fact as to whether Plaintiff defaulted on his loan; (2) the foreclosure sale was lawfully noticed; and (3) Bank of America was the holder of the note at the time of foreclosure. View "McGovern v. Bank of Am., N.A." on Justia Law

In 1998, the Department of Environmental Management (DEM) and John, Alfred, and Anna Tillinghast (Defendants) executed a consent agreement regarding the actions Defendants would take to remedy alleged violations of the Freshwater Wetlands Act from the establishment of five campsites in the Bowdish Lake Camping Area. When Defendants purportedly failed to comply with the consent agreement, the superior court appointed a master to resolve the issues in dispute. The master issued a report, and Defendants filed a motion asking the trial justice to approve the master’s report. After a hearing, the trial justice adopted the report and ordered that the master’s findings be implemented. Plaintiff, named in her official capacity as the director of the DEM, appealed. The Supreme Court denied and dismissed the appeal, holding that because the order confirming the master’s report was not final, the appeal was interlocutory and thus not properly before the Court. View "Coit v. Tillinghast" on Justia Law

After J.S., a juvenile, injured an individual with a knife, the state police filed two petitions against J.S., including a petition alleging that J.S. was delinquent due to having committed an offense that, if committed by an adult, would constitute an assault with a dangerous weapon. The family court found J.S. delinquent for committing an assault with a dangerous weapon and placed him on probation. The Supreme Court affirmed, holding that there was sufficient legally competent evidence to support (1) the trial justice’s finding that the State presented sufficient evidence to disprove J.S.’s defense of self-defense beyond a reasonable doubt, and (2) the trial justice’s adjudication of Respondent as delinquent for having committed an assault with a dangerous weapon. View "In re J.S." on Justia Law

Plaintiff-general contractor entered into an agreement with Defendant-subcontractor to perform work on a project. A dispute arose between the parties when Plaintiff issued Defendant a notice of termination. The issue was submitted to arbitration, and both parties submitted claims to the arbitrator for money damages. The arbitrator found that Plaintiff’s termination of Defendant was wrongful and granted damages. Plaintiff sought to vacate the arbitrator’s award. The trial court concluded that a release signed by Defendant that waived all claims prior to a certain date barred Defendant’s claims. The Supreme Court vacated the judgment of the superior court, holding that the arbitrator’s decision should have been allowed to stand because it showed due regard for the parties’ release and did not reach an irrational result. View "Berkshire Wilton Partners, LLC v. Bilray Demolition Co." on Justia Law

Plaintiffs agreed to lease medical diagnostic imaging equipments to Defendants for use in a medical imaging center. The center proved to be unsuccessful shortly after it opened, and Defendants defaulted on their payments. Plaintiffs filed a fourteen-count complaint against Defendants that included counts for replevin, breach of contract, breach of consent to sublease, and breach of sublease. Defendants counterclaimed for intentional misrepresentation, negligent misrepresentation, fraud and deceit, and a violation of Mass. Gen. Laws ch. 93A. The superior court granted summary judgment for Plaintiffs on all claims and counterclaims. The Supreme Court affirmed, holding that there were no genuine issues of material fact, and therefore, summary judgment was proper on Plaintiffs’ claims and Defendants’ counterclaims. View "Siemens Fin. Servs., Inc. v. Stonebridge Equip. Leasing, LLC " on Justia Law

At issue in this case was which party was entitled to insurance funds under an insurance policy on a parcel of property that sustained water damage. Stanley Gurnick and Phoenix-Gurnick, RIGP claimed they owned the property as a result of a foreclosure sale. Navigant Credit Union claimed it was entitled to the funds as the named mortgagee/loss payee in the insurance policy. The superior court decided that Navigant was entitled to the insurance proceeds because the funds were personal property under the insurance contract and Navigant was named a loss payee under that contract. The Supreme Court affirmed, holding that the hearing justice correctly determined that Navigant was entitled to the insurance proceeds. View "R.I. Joint Reinsurance Ass’n v. O’Sullivan" on Justia Law

After a trial, the family court dissolved the twenty-four year marriage of Husband and Wife. Both parties appealed the family court’s decision. The Supreme Court affirmed in part and reversed in part the decision pending entry of final judgment, holding that the trial justice (1) did not overlook or misconceive the medical evidence relating to Wife’s medical condition; (2) did not err in distributing the property; (3) did not err by retroactively applying a modification of child support; (4) did not err by failing to award Wife lifelong medical coverage and attorney’s fees; and (5) made an inequitable sua sponte modification concerning the termination of alimony. View "Bober v. Bober" on Justia Law

The Federal Aviation Administration (FAA) requires that all pilots obtain and maintain a valid medical certificate. After he was involved in motor-vehicle accident, Plaintiff, a commercial pilot, surrendered his medical certificate at the request at the FAA. Plaintiff subsequently sought reinstatement from the FAA. The FAA retained Defendant, a physician, as a medical consultant to opine whether Plaintiff met the FAA’s criteria for alcohol dependence. After reviewing certain medical documents, Defendant determined that Plaintiff was substance dependent. Plaintiff sued Defendant, alleging that Defendant was negligent in making his report and that the FAA had relied on Defendant’s conclusion to Plaintiff’s detriment. The superior court denied Defendant’s motion for summary judgment, concluding that Defendant owed Plaintiff a duty of care to accurately reach or report the conclusions of his records review. The Supreme Court quashed the order of the superior court, holding that Defendant did not owe Plaintiff a duty of care in this case. View "Woodruff v. Gitlow" on Justia Law

In 1998 after a plea hearing, the hearing justice accepted Amadeu Santos’s plea of nolo contendere to three counts of second-degree sexual assault. In 2012, Santos filed an application for postconviction relief, asserting that the 1998 plea colloquy did not comply with the Superior Court Rules of Criminal Procedure. The hearing justice denied Santos’s application, finding that it was barred by the doctrine of laches. The Supreme Court affirmed, holding that the hearing justice’s decision regarding the unreasonableness of Santos’s delay was not clearly wrong, nor did it constitute an abuse of discretion. View "Santos v. State" on Justia Law

Plaintiff executed a promissory note in favor of EquiFirst, secured by a mortgage on real estate. The mortgage designated EquiFirst as the Lender and named Mortgage Electronic Registration Systems (MERS) as the mortgagee and the Lender’s nominee. MERS, as EquiFirst’s nominee, assigned the mortgage to Sutton Funding, which assigned the mortgage to Bank of New York Mellon Trust Company (Bank of New York). Bank of New York subsequently initiated a foreclosure sale, at which it prevailed as the highest bidder. Plaintiff filed suit in the superior court challenging the validity of the two mortgage assignments. The hearing justice dismissed Plaintiff’s complaint under Sup. Ct. R. Civ. P. 12(b)(6), concluding that the assignments were valid, and additionally dismissed Plaintiff’s complaint under Rule 12(b)(7) for failing to join an indispensible party, Bank of New York. The Supreme Court affirmed the dismissal on the basis of Rule 12(b)(7), holding that hearing justice’s dismissal on Rule 12(b)(7) grounds was appropriate where Plaintiff failed to join Bank of New York to the action. View "Rosano v. Mortgage Elec. Registration Sys., Inc." on Justia Law