Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of one count of first-degree child molestation and three counts of second-degree child molestation. On appeal, Defendant argued that the trial justice abused her discretion in refusing to exclude all evidence of uncharged acts of molestation and that the trial justice erred in denying Defendant’s motion for judgment of acquittal and Defendant's motion for a new trial. The Supreme Court affirmed, holding (1) Defendant’s first argument was not preserved for appeal; and (2) the trial justice did not err in denying Defendant’s motions for judgment of acquittal and a new trial. View "State v. Buchanan" on Justia Law

After a jury trial, Defendant was convicted of second-degree child molestation sexual assault. Defendant appealed, arguing that the trial justice erred when she allowed the State to elicit testimony from the complaining witness, which Defendant alleged violated Sup. Ct. R. Crim. P. 16 because the testimony was contrary to the State’s supplemental discovery responses. The Supreme Court affirmed the judgment of the superior court because the content of and the inconsistency among the complaining witness’s statements was disclosed to Defendant and was a proper subject for cross-examination. View "State v. Santiago" on Justia Law

Defendant and the complaining witness (Complainant) lived together while Defendant maintained his own apartment. Due to certain incidents between Defendant and Complainant, Defendant was convicted after a jury trial of one count of simple domestic assault. Defendant appealed, arguing that the trial justice erred in denying his motion for acquittal and in denying his motion for a new trial because the evidence presented at trial did not establish that Defendant and Complainant were in a domestic relationship, as required under R.I. Gen. Laws 12-29-2. The Supreme Court affirmed the judgment of conviction, holding that the trial justice properly found Defendant and Complainant were in a domestic relationship.View "State v. Fleck" on Justia Law

After a jury trial, Defendant was convicted of four counts of first-degree sexual assault and one count of felony assault and battery for his brutal attack of a sixteen-year-old girl. Two years after the attack, law enforcement performed a buccal swab on Defendant, which matched the profile developed from a sample taken from the victim’s underwear. As a result, Defendant was indicted on seven felony counts. The Supreme Court affirmed the judgment, holding (1) the trial justice did not err in denying Defendant’s motion for judgment of acquittal based on the sufficiency of the evidence and Defendant’s motion for a new trial based on alleged errors occurring at trial; and (2) the trial justice did not err in denying Defendant’s motion to exclude the testimony of a forensic evidence analyst who testified at trial. View "State v. Nickerson" on Justia Law

Petitioner applied to the Town of Scituate building official for a building permit to build a single-family home on an unimproved lot. The building official denied the permit, citing numerous deficiencies with Petitioner's plans, including a lack of street frontage. Petitioner appealed the denial and, alternatively, applied for a dimensional variance. The town zoning board denied the appeal and the request for a dimensional variance. The superior court affirmed. The Supreme Court vacated the judgment of the superior court, concluding that the zoning board abused its discretion in determining that a frontage requirement was required for Petitioner's property. Remanded.View "Iadevaia v. Town of Scituate Zoning Bd. of Review" on Justia Law

In 2006, Ingram executed a promissory note in favor of Loancity in the amount of $212,500 to finance the purchase of property in Providence and executed a mortgage on the property. The documents identified Mortgage Electronic Registration Systems (MERS) as “a separate corporation that is acting solely as nominee for Lender and Lender’s successors and assigns.” After a series of assignments in 2009, Deutsche Bank held both the note and the mortgage to the property. Ingram failed to make the required payments. OneWest, under power of attorney for Deutsche Bank, mailed notice that a foreclosure sale on the property was scheduled for March 25, 2010. The foreclosure sale was advertised in the Providence Journal. At the scheduled sale, Deutsche Bank purchased the property for $95,066.40. Ingram sought declaratory relief and to quiet title to the property. The superior court dismissed. The Rhode Island Supreme Court affirmed, rejecting various allegations of improper procedure. View "Ingram v. Mortg. Elec. Registration Sys., Inc" on Justia Law

Pawtucket police officer Laprade was convicted of disorderly conduct, stemming from a 2010 incident, during which two women observed the off-duty Laprade masturbating and exposing himself while driving his personal vehicle. The city charged Laprade with violations of regulations stemming from that conviction and other incidents, including sleeping while on duty. After being notified of the city’s recommendation that his employment be terminated, Laprade requested a hearing under the Law Enforcement Officers’ Bill of Rights Act (LEOBOR), G.L. 42-28.6-4. A committee was selected. Nine days before the scheduled hearing and one day after the statutory deadline, the city provided Laprade with a list of its witnesses and evidence. Because of the timing and a personal conflict, a member of the committee unsuccessfully sought a continuance. Although no complaint or petition had been filed, the Presiding Justice of the Superior Court issued an order stating that failure to present the list 10 days before the hearing date did not present good cause to extend the date. The committee refused to accept evidence on the first scheduled date. Ultimately the committee found that, due to procedural errors, the city had not proven its case. The superior court affirmed. The Rhode Island Supreme Court vacated, based on procedural errorsView "City of Pawtucket v. Laprade" on Justia Law

Plaintiff, who was injured while working as a deckhand on a commercial vessel, sued Defendant, Huntress, Inc., for maintenance and cure, negligence under the federal Jones Act, and breach of the warranty of seaworthiness. After a trial, Plaintiff prevailed on his claim for maintenance and cure but not on his remaining claims. The trial justice subsequently denied Defendant’s motion for a new trial with respect to the claim for maintenance and cure and granted Plaintiff’s motion for a new trial with respect to the claims for negligence and breach of the warranty of seaworthiness. The Supreme Court (1) vacated the trial justice’s denial of Defendant’s motion for a new trial with respect to the claim for maintenance and cure, holding that the trial justice gave an improper instruction to the jury regarding “unearned wages,” and the error resulted in prejudice to Defendant; and (2) vacated the trial justice’s grant of Plaintiff’s motion for a new trial on the claims of negligence under the Jones Act and breach of the warranty of seaworthiness, holding that the trial justice overlooked and misconceived testimony, resulting in a decision that was clearly wrong. View "King v. Huntress, Inc." on Justia Law

Defendant agreed to furnish labor, materials, equipment, and services for a pipe-replacement project at Brown University. Defendant entered into a sub-contract with Plaintiff in which Plaintiff agreed to install the pipe. After Plaintiff completed its portion of the project, Plaintiff filed breach of contract and quantum meruit claims against Defendant, alleging that Defendant failed to pay for some of the work that Plaintiff performed on the project. The superior court entered judgment in favor of Plaintiff on its quantum meruit claim. The Supreme Court affirmed, holding that the trial justice did not misapply the law, misconceive or overlook material evidence, or make factual findings that were clearly wrong in reaching its decision. View "Process Eng’rs & Constructors, Inc. v. DiGregorio, Inc." on Justia Law

This case involved an ongoing dispute between two commercial landowners, Plaintiff and Defendant, over the existence of a prescriptive easement used by delivery trucks to access a loading dock owned by Plaintiff. After Defendant ordered the installation of barriers along the southwestern boundary of an express easement, it was nearly impossible for delivery vehicles to directly access the loading dock. Plaintiff filed a complaint, claiming a prescriptive easement over Defendant’s lot. In his second decision, the trial justice denied Plaintiff’s claim for a prescriptive easement. The Supreme Court affirmed, holding that Plaintiff failed to meet its burden of proof on the element of hostility, and therefore, Plaintiff could not succeed on its claim. View "Butterfly Realty v. James Romanella & Sons, Inc." on Justia Law