Justia Rhode Island Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of murder, assault with a dangerous weapon, and other crimes arising out of a shooting outside of a nightclub. The Supreme Court affirmed the judgment of conviction, holding (1) the trial justice did not err when he denied a motion to suppress out-of-court and in-court identifications, as the photographic array displayed to the witness was not unnecessarily suggestive; and (2) the trial justice did not err when he permitted the state to use peremptory challenges to African-American prospective jurors, as the challenges did not violate the Equal Protection Clause of the United States Constitution. View "State v. Gallop" on Justia Law

In 2006, the family court entered final judgment on a divorce between Sandra Carney and Stephen Carney that incorporated by reference a marriage settlement agreement (MSA) entered into by the parties. In 2011, Stephen filed a motion to enforce the MSA or, in the alternative, to adjudge Sandra in contempt, arguing that Sandra failed to comply with the MSA because she did not pay an equitable distribution to him upon her sale of the parties’ former marital domicile. The trial justice determined that Stephen was entitled to payment from Sandra under the terms of the MSA and gave Sandra until 2012 to produce the amount of $59,375 to Stephen. The Supreme Court reversed in part the order of the family court, holding (1) the trial justice did not make sufficient factual findings on the record with respect to the intent of the parties at the time they entered into the agreement regarding the timing of the payment of the equitable distribution; and (2) the trial justice erred in her calculation of the amount Sandra owed to Stephen for the sale of the house. View "Carney v. Carney" on Justia Law

Plaintiffs purchased a home that a pre-closing inspection revealed had corrosion on the oil heating system in the basement. Although the boiler and oil tank were replaced prior to the sale of the home, the oil feed line buried beneath the concrete floor in the basement was not replaced. After Plaintiffs discovered an oil leak at the feed line, they initiated claims under their homeowners’ insurance policy issued by Defendant. Defendant denied Plaintiffs’ claim. Plaintiffs filed a complaint against Defendant for breach of contract. The trial justice granted summary judgment in favor of Defendant, concluding that Plaintiffs’ claim was caused by gradual corrosion of an oil fuel feed line, not by a sudden or accidental loss, and the claim was therefore barred by the clear and unambiguous terms of the policy. The Supreme Court affirmed, holding that because the undisputed evidence indicated that the damage to Plaintiffs’ property was caused by corrosion, which was not covered by their insurance policy, there were no genuine issues of material fact, and Defendant was entitled to judgment as a matter of law. View "Nunez v. Merrimack Mut. Fire Ins. Co." on Justia Law

In 2007, Defendant entered a plea of nolo contendere to one count of possession of a controlled substance, for which he was sentenced to five years probation. In 2011, the superior court entered a judgment of conviction declaring Defendant to be in violation of the terms of his probation and sentencing Defendant to five years of his previously suspended sentence. Defendant appealed, arguing that the hearing justice acted arbitrarily and capriciously in finding that he violated the terms of his probation. The Supreme Court affirmed, holding that the hearing justice acted neither arbitrarily nor capriciously in finding that Defendant violated the terms and conditions of his probation. View "State v. Barrientos" on Justia Law

After a jury trial, Defendant was convicted of two counts of second-degree sexual assault. Defendant subsequently filed a motion for a new trial, arguing that testimony given by certain witnesses was contradictory, that the police department’s investigation of the incident was flawed, and that he was innocent. The trial justice ultimately denied Defendant’s motion. On appeal, Defendant challenged only the trial justice’s denial of his motion for a new trial. The Supreme Court affirmed the superior court’s judgment of conviction, holding that the trial justice in this credibility-intensive case was not clearly wrong, nor did he overlook or misconceive material and relevant evidence in denying Defendant’s motion for a new trial. View "State v. Barrios" on Justia Law

In 2005, the Rhode Island Department of Administration and the Rhode Island Department of Health (collectively, the State), selected Plaintiff as its livery service provider through a bidding process. Plaintiff and the State entered into a contract setting forth the terms of the parties’ agreement. In 2007, the State terminated Plaintiff’s contract for alleged violations of the terms of the bid award. Plaintiff filed suit, alleging that the State breached the contract by terminating the agreement in bad faith and without cause. Before trial, the trial justice granted the State’s motion in limine to prohibit Plaintiff from introducing evidence to suggest that the contract was an exclusive agreement between the State and Plaintiff. The trial justice subsequently found that the State lawfully terminated its contract with Plaintiff in good faith and did not breach the contract. The Supreme Court affirmed, holding that the trial justice did not err in finding that the contract was not exclusive and that the State’s unilateral termination of the contract upon a finding of unsatisfactory performance did not constitute a breach. View "JPL Livery Servs., Inc. v. R.I. Dep’t of Admin." on Justia Law

Plaintiff, acting as subcontractor to Builder, performed work on a property in the City of Providence owned by Owner and leased by Lessee. A dispute subsequently arose regarding payment, and Plaintiff sought to enforce a mechanics’ lien against Owner, Lessee, and Builder. After Owner and Lessee deposited a bond, with Liberty Mutual Insurance Company as surety, the superior court discharged the lien. Plaintiff subsequently amended its complaint to add Liberty as a defendant. Plaintiff then moved for partial summary judgment on the mechanics’ lien claim. The trial justice denied Plaintiff’s motion for summary judgment and entered final judgment in favor of Owner and Lessee. Plaintiff appealed, arguing that the superior court erred in entering judgment in favor of Owner and Lessee because they, as well as Builder and Liberty, were all directly liable to it for any rights it had under the lien statute. The Supreme Court affirmed, holding that the plain language of the mechanics’ lien statute mandates the dismissal and discharge of the lien once a bond, which replaces the property as security for the claim, is deposited with the registry of the court. View "Nat’l Refrigeration, Inc. v. Capital Props., Inc." on Justia Law

Plaintiff filed a complaint against Metropolitan Property and Casualty Insurance Company and other defendants, alleging multiple counts. A jury found Defendants liable for abuse of process and awarded compensatory and punitive damages against each defendant. On May 31, 2012, judgments were entered against Defendants. On August 31, 2012, Metropolitan filed an appeal from the May 31, 2012 judgment, and on September 18, 2012, Plaintiff filed a notice of cross-appeal from the May 31, 2012 judgment. Metropolitan moved to dismiss Plaintiff’s cross-appeal, arguing that it was untimely because it was not filed within the initial twenty-day appeal period that began to run after entry of the August 20, 2012 orders. The trial justice denied Metropolitan’s motion to dismiss, concluding that Plaintiff’s cross-appeal was timely because it was filed within twenty days of Metropolitan’s August 31, 2012 notice of appeal. The Supreme Court affirmed, holding that Plaintiff’s September 18, 2012 notice of cross-appeal was timely because it was filed within the twenty-day period triggered by Metropolitan’s August 31, 2012 notice of appeal. View "Miller v. Metro. Prop. & Cas. Ins. Co." on Justia Law

Defendant was charged with ten offenses in a single indictment. After five of the counts were dismissed, the jury returned guilty verdicts on the five remaining counts of first-degree murder, first-degree robbery, and reckless driving, among other crimes. The trial justice sentenced Defendant to life for the murder conviction. The Supreme Court affirmed the judgments of conviction, holding that the trial justice (1) did not err when he did not grant Defendant’s motion to sever the counts relating to the murder/robbery from the counts relating to the police chase; (2) did not err by not granting Defendant’s motion to sever certain offenses committed on one date from offenses committed on another date; (3) did not violate Defendant’s right to a fair trial when he refused to allow a police artist’s sketch into evidence; (4) did not err when he denied Defendant’s motion to exclude three autopsy photographs from evidence; and (5) did not err in denying Defendant’s motion for a new trial. View "State v. Brown" on Justia Law

In 2009, three men attacked and robbed Complainant. Several days later, Complainant saw one of his attackers loitering on the street. After a foot chase, Complainant caught the attacker - Michael Long - and held him until the police arrived. Upon his arrest, Long implicated Defendant in the crime. After a jury trial, Defendant was convicted of one count of first-degree robbery. The Supreme Court affirmed the conviction, holding (1) Defendant waived his double jeopardy challenge; (2) the trial justice did not abuse her discretion by admitting Long’s prior police statement as a prior inconsistent statement, and the use of Long’s prior police statements as prior inconsistent statements did not violate the Confrontation Clause; (3) any use of leading questions posed to Long by the prosecutor was harmless; (4) the trial justice did not err by admitting Long’s statements to his former finacee in the presence of Defendant as adoptive admissions; and (5) the trial justice did not err by denying Defendant’s motion for a new trial. View "State v. Matthews" on Justia Law