Justia Rhode Island Supreme Court Opinion Summaries

A work van being driven by cable installer Nelson Ovalles collided with a car being driven by Barbara Cayer. Cayer filed a lawsuit against Ovalles and the company on whose behalf Ovalles apparently performed cable-installation work, Cox Rhode Island Telecom, LLC (“Cox”). Cox filed a motion for summary judgment, arguing that it could not be vicariously liable for Ovalles’s actions because it did not own the vehicle or have an employment relationship with Ovalles. The superior court granted the motion. Cayer appealed, contending (1) genuine issues of material fact existed as to whether Ovalles was Cox’s employee at the time of the accident, and (2) the superior court erred by denying her motion to amend her complaint to assert claims against a contractor for Cox. The Supreme Court (1) affirmed the grant of summary judgment in favor of Cox because Ovalles could not be considered Cox’s employee; and (2) denied and dismissed the appeal with regard to the motion to amend, holding that it was improperly before the Court because the order denying Cayer’s motion to amend did not fall within an exception to the final-judgment rule.View "Cayer v. Cox R.I. Telecom, LLC" on Justia Law

Mary Cummings, a participant in a charitable fundraising walk for the benefit of Defendants, was injured when she was struck by a vehicle operated by James Brown, an employee of Bluelinx Corporation. Cummings settled all claims against all Defendants. Brown and Bluelinx then filed suit against Defendants seeking contribution toward the settlement. A jury found that Defendants’s negligence was the proximate cause of Cummings’s injuries and apportioned Defendants’ fault at twenty percent. The superior court subsequently granted Defendants’ renewed motion for judgment as a matter of law, finding that there was not a legally sufficient basis for the jury’s verdict. The Supreme Court affirmed, holding that, as a matter of law, there was no cognizable duty of care owed by Defendants in this case.View "Brown v. Stanley" on Justia Law

Plaintiffs entered into a loan agreement with Potomac Realty Capital LLC (PRC) to rehabilitate and renovate certain property. As security for the loan, NV One granted a mortgage on the property. Plaintiffs later filed a complaint against PRC, asserting violations of the Rhode Island usury law, among other claims. The trial justice granted summary judgment to Plaintiffs with respect to the usury claim, entered an order declaring the loan usurious and void, and voided the mortgage. At issue on appeal was whether a usury savings clause in the loan document validated the otherwise usurious contract. The Supreme Court affirmed, holding that Plaintiffs were entitled to judgment as a matter of law on their usury claim because (1) the loan was a usury; and (2) the usury savings clause was unenforceable on public policy grounds.View "NV One, LLC v. Potomac Realty Capital, LLC" on Justia Law

Defendant was charged with one count of second-degree sexual assault. A jury trial commenced, but the trial justice granted Defendant’s motion for a mistrial due to a discovery violation. Thereafter, Defendant moved to dismiss the sexual-assault charge on double jeopardy grounds because of prosecutorial goading. The trial justice denied Defendant’s motion. The Supreme Court upheld the trial justice’s denial of Defendant’s motion to dismiss the charge, holding that sufficient evidence in the record supported the trial justice’s finding that the objective facts did not give rise to an inference of intentional goading.View " State v. Rolle" on Justia Law

Plaintiff and Defendants were owners of property with a common boundary. Plaintiff and Defendants disputed the location of the boundary line, and Plaintiff claimed Defendants encroached upon her property. When Defendants obtained a building permit to construct a building on their alleged property, Plaintiff filed suit seeking declaratory and injunctive relief. The superior court granted injunctive relief to Plaintiff, permanently enjoined Defendants from trespassing on Plaintiff’s lot, ordered the removal of the portion of Defendants’ building that encroached on Plaintiff’s lot, and awarded damages to Plaintiff. The Supreme Court affirmed, holding that the trial justice did not err (1) in finding that the boundary line established by a survey initiated by Plaintiff constituted the boundary line between the two lots; and (2) in awarding damages to Plaintiff based on the diminution in the fair market value of her land as a result of the encroachment by Defendants. View "Banville v. Brennan" on Justia Law

Plaintiffs executed a mortgage identifying Domestic Bank as the lender and Mortgage Electronic Registration Systems, Inc. as a corporation “acting solely as nominee” for the lender and the lender’s assigns. Later, MERS purported to assign the mortgage to Aurora Loan Services, LLC (Aurora). Aurora “or the successful bidder” allegedly took a foreclosure deed at a subsequent foreclosure sale. Plaintiffs filed a complaint against MERS seeking a declaration that the assignment and foreclosure sale were void and that Plaintiffs owned a fee simple interest in the property. The superior court dismissed the complaint, concluding (1) Plaintiffs did not have standing to seek relief based on the assignment because they were neither an assignor nor an assignee of the assignment; and (2) even if Plaintiffs had standing, their allegations were insufficient to survive a motion to dismiss. The Supreme Court vacated the judgment of the superior court, holding (1) Plaintiffs had standing to prosecute their claim; and (2) Defendants’ Rule 12(b)(6) motion was improperly granted because Plaintiffs’ complaint stated a plausible claim upon which relief could be granted.View "Chhun v. Mortgage Elec. Registration Sys., Inc." on Justia Law

After a jury trial, Defendant was convicted of two counts of murder, and one count each of conspiracy and arson. The trial justice sentenced Defendant to three consecutive life sentences. The Supreme Court affirmed, holding (1) the admission of evidence of a robbery Defendant committed the day before the murders, even if error, was harmless beyond a reasonable doubt; (2) Defendant failed to preserve his objections to the content of the limiting instructions regarding the use of the robbery evidence; and (3) the trial justice did not abuse his discretion when he denied Defendant’s motion to pass the case.View "State v. Clements" on Justia Law

After a jury trial, Defendant was convicted of six criminal counts relating to a shooting. Defendant appealed, arguing that, in denying his motion for a new trial, the trial justice overlooked and misconceived material evidence and failed to draw appropriate inferences from the evidence. Specifically, Defendant argued that the testimony of two key witnesses at trial was not credible. The Supreme Court affirmed, holding that nothing in the record showed the justice was either clearly wrong or that the justice overlooked or misconceived material and relevant evidence in his denial of Defendant’s motion for a new trial.View "State v. Silva" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree child molestation sexual assault. Defendant appealed, contending, among other things, that the trial justice erred when it denied his motion to suppress statements made to police during a post-arrest interrogation. The Supreme Court (1) affirmed the trial justice’s denial of Defendant’s motion for a new trial and discerned no error arising from the justice’s evidentiary rulings; but (2) remanded the case to the superior court with directions to make additional findings of fact and credibility determinations concerning the voluntariness of Defendant’s confessions, as the trial justice failed to make the findings of fact and credibility determinations essential to support his ultimate finding of voluntariness. View "State v. Bojang" on Justia Law

In 1994, Defendant was charged with felony assault with a dangerous weapon (Count One) and willful or malicious injury to property (Count Two). Count One was dismissed in consideration of Defendant pleading nolo contendere to Count Two. In 2004, Defendant filed a motion to seal with respect to both counts. A justice of the superior court denied the motion. Defendant appealed the hearing justice’s denial of her motion with respect to Count One. The Supreme Court affirmed, holding that the hearing justice did not err when she denied Defendant’s motion to seal Count One pursuant to R.I. Gen. Laws 12-1-12.1(a) because Defendant had not been exonerated of all counts in the criminal case.View "State v. Diamante" on Justia Law