Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of two counts of first-degree child molestation sexual assault. Defendant subsequently moved for a new trial, asserting that the verdict failed to respond to the evidence and failed to do substantial justice between the parties. The trial justice denied Defendant’s motion for a new trial. On appeal, Defendant challenged only the trial justice’s denial of his motion for a new trial. The Supreme Court affirmed the judgment of conviction, holding that the trial justice did not overlook or misconceive the material evidence and conducted the proper analysis in denying Defendant’s motion. View "State v. Lake" on Justia Law

Frederick Carrozza, Sr. filed a petition seeking to impose a resulting trust on four properties and caused notices of lis pendens to be filed with respect to each of the properties at issue. Counterclaimants, in turn, filed a counterclaim alleging slander of title. Summary judgment was granted in favor of Counterclaimants with respect to the resulting trust issue. After a trial on the slander of title counterclaim, the trial justice held the counterclaim defendants - Frederick Sr. and his three living children - liable for slander of title. The Supreme Court affirmed the judgment of the superior court in all respects except that part of the judgment awarding $845,00 in punitive damages, holding that the award of punitive damages should be reduced to $422,500. View "Carrozza v. Voccola" on Justia Law

David Alba was appointed to serve as principal of an elementary school in Cranston, Rhode Island. Alba and the Cranston School Committee subsequently entered into an employment contract. Later, after a hearing, the Committee rejected a recommendation to renew Alba’s employment contract. Alba appealed the Committee’s decision. The Commissioner of Education denied and dismissed Alba’s appeal, concluding that Alba had received all the process to which he was entitled under the contract and the School Administrators’ Rights Act. The Board of Regents affirmed the Commissioner’s decision. The Supreme Court affirmed, holding (1) the Committee acted within its authority when it voted against the recommendation to renew Alba’s contract; and (2) the Committee’s nonrenewal of Alba’s contract did not deprive Alba of his rights under the Administrators’ Rights Act. View "Alba v. Cranston Sch. Comm." on Justia Law

In 1990, Appellant was convicted of several criminal charges. Appellant was sentenced to thirty years’ imprisonment, with fifteen years to serve and fifteen years suspended. After Appellant was released from prison a justice of the superior court determined that Appellant had violated the terms and conditions of his probation and vacated the suspension of the remaining fifteen years of Appellant’s original sentence. One year later, Appellant filed an application for postconviction relief. An attorney was appointed to represent Appellant in his application but later filed a motion to withdraw, asserting that Appellant’s grounds for relief lacked merit. After a hearing, the attorney was allowed to withdraw. Appellant’s application for postconviction relief was ultimately denied. Appellant appealed, arguing that the hearing justice erred when she allowed Appellant’s attorney to withdraw. The Supreme Court affirmed, holding that the hearing justice was not clearly wrong and did not overlook or misconceive material evidence when she concluded that Appellant’s application lacked merit and granted Appellant’s attorney’s motion to withdraw. View "Roscoe v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder and sentenced to life imprisonment. Appellant filed a pro se application for postconviction relief alleging that he received ineffective assistance of counsel at trial. Appellant also filed a motion to appoint counsel. Counsel was appointed to investigate Appellant’s postconviction-relief claims in light of the Court’s holding in Shatney v. State. Counsel subsequently filed a Shatney report and requested that the court permit her to withdraw her appearance on Appellant’s claims of ineffective assistance of counsel. The trial court allowed counsel to withdraw from the case, and Appellant proceeded pro se on his postconviction relief claims. Following a hearing, the trial justice denied and dismissed Appellant’s application for postconviction relief. The Supreme Court vacated the judgment of the superior court, holding that the trial justice did not follow the appropriate procedure mandated by Shatney by not allowing Appellant an opportunity to be heard on the merits of his application before allowing the appointed attorney to withdraw. Remanded with directions to appoint counsel to Appellant in accordance with section R.I. Gen. Laws 10-9.1-5 for investigation and, if appropriate, litigation of Appellant’s allegations. View "Ramirez v. State" on Justia Law

Plaintiff was crossing a street when she was struck by a vehicle operated by John Faelle, owned by Hertz Corporation, and purportedly rented to Anthony Carroccio. Plaintiff filed an action against Faelle, Hertz, and Carroccio. Hertz moved for summary judgment, arguing that it did not consent to Faelle’s operation of the vehicle that struck Plaintiff and, alternatively, that 49 U.S.C. 30106, the Graves Amendment, precluded the vicarious liability of Hertz as the owner of the vehicle. The superior court granted Hertz’s motion for summary judgment. The Supreme Court reversed, holding that summary judgment was not appropriate where (1) Hertz’s consent to Faelle’s operation of the vehicle remained an issue of material fact; and (2) the rental record did not establish the period of the rental for purposes of the Graves Amendment because it did not identify the vehicle involved in the accident. Remanded for trial. View "Marble v. Faelle" on Justia Law

Plaintiffs, school committees of Woonsocket and Pawtucket and unnamed students, parents, and the superintendents from both districts, brought suit against the legislative and executive branches of Rhode Island’s state government challenging the state’s school funding formula. Specifically, Plaintiffs alleged violations of the Education Clause as well as violations of their substantive due process and equal protection rights because the formula failed to allocate adequate resources to less affluent communities. The superior court granted Defendant’s motion to dismiss the complaint. The Supreme Court affirmed, holding (1) prior case law as well as the separation of powers doctrine warranted dismissal of Plaintiffs’ Education Clause claim; and (2) Plaintiffs’ complaint was insufficient to establish potential substantive due process claims. View "Woonsocket Sch. Comm. v. Chafee " on Justia Law

After a jury trial, Defendant was found guilty of resisting arrest. Defendant appealed, arguing that the trial justice (1) abused his discretion by permitting the state to admit into evidence Defendant’s prior convictions; and (2) erred in permitting the prosecutor to reveal that two of Defendant’s prior assault convictions were upon police officers. The Supreme Court vacated the judgment of conviction, holding that the trial justice (1) was not clearly wrong in admitting the prior conviction evidence; but (2) erred in permitting the state to impeach Defendant’s testimony using his prior convictions of assault against police officers, and the error was not harmless. Remanded for a new trial. View "State v. Mercurio" on Justia Law

After a jury trial, Defendant was convicted of assault with a dangerous weapon, using a firearm during a crime of violence, and carrying a firearm without a license. Defendants convictions arose out of a shooting inside the lobby of a hotel/nightclub. In 2011, Defendant requested a new trial based on allegedly newly discovered evidence that, sometime before trials, federal marshals had visited the apartment of one of the state’s witnesses. Defendant claimed that the visit from the marshals gave the witness a motive to falsely inculpate Defendant in the shooting. The trial justice denied Defendant’s request for a new trial, concluding that the information about the marshals did not constitute newly discovered evidence. The Supreme Court affirmed, holding that there was neither clear error nor a misconception of material evidence in the trial justice’s denial of Defendant’s motion for a new trial. View "State v. Quaweay" on Justia Law

Plaintiffs filed suit, individually and per proxima amici, against numerous defendants, alleging, inter alia, negligence, lack of informed consent, and vicarious liability for injuries sustained by their minor daughter, Yendee, who was born with a genetic blood disorder. Four groups of defendants filed motions to dismiss on the grounds that R.I. Gen. Laws 9-1-14.1(1), an act that tolls the three-year statute of limitations for medical malpractice claims when the person claiming injury is a minor, barred Plaintiffs’ claims. The trial justice entered judgment in favor of Defendants, concluding that all of Plaintiffs’ claims were time-barred but that Yendee retained the right to bring suit on her own behalf when she reached the age of majority, and up to three years thereafter. After issuing an order to show cause, the Supreme Court (1) vacated the judgments entered in favor of defendants Corning Incorporated and Quest Diagnostics, LLC because Plaintiffs’ allegations against these defendants were not medical malpractice claims; and (2) directed that Plaintiffs’ appeal, as well as the appeals and cross-appeals of Rhode Island Hospital, Miriam Hospital, Women & Infants Hospital and each hospital’s associated medical professionals, be assigned to the Court’s regular calendar for further briefing and argument. View "Ho-Rath v. R.I. Hosp." on Justia Law