Rhode Island Case Commentaries

Corporate Fleet UIM Stacking Barred for Employee-Occupants: § 27-7-2.1(i) Inapplicable Absent Premium Payment by the Insured

Date: Aug 1, 2026

Corporate Fleet UIM Stacking Barred for Employee-Occupants: § 27-7-2.1(i) Inapplicable Absent Premium Payment by the Insured Introduction In Shilo D. Horsman, individually, and in her capacity of as...

§ 9-19-27 Does Not Govern Medical Records Used Solely for Impeachment; Party Testimony Can Supply Rule 901 Authentication

Date: Aug 1, 2026

§ 9-19-27 Does Not Govern Medical Records Used Solely for Impeachment; Party Testimony Can Supply Rule 901 Authentication Case: Yohaira Galindez v. Rhode Island Public Transit Authority et al. Court:...

GARA Misrepresentation Exception Requires Specific Fact Pleading Before Discovery; “New Parts” Rolling Provision Demands Proof of Manufacturer and Causation

Date: Aug 1, 2026

GARA Misrepresentation Exception Requires Specific Fact Pleading Before Discovery; “New Parts” Rolling Provision Demands Proof of Manufacturer and Causation 1. Introduction In Carol Williams,...

Home-Rule Limit on Special Acts: Single-City, Single-Beneficiary Legislation Is Void Without Local Voter Approval (R.I. Const. art. 13, § 4)

Date: Jul 31, 2026

Home-Rule Limit on Special Acts: Single-City, Single-Beneficiary Legislation Is Void Without Local Voter Approval (R.I. Const. art. 13, § 4) 1. Introduction In Myles Standish Associates, LP v. The...

Insurer May Litigate Newly Pleaded Fraud in Declaratory Judgment; Appraisal Is Premature Until Coverage and Timing of Loss Are Proven

Date: Jul 31, 2026

Insurer May Litigate Newly Pleaded Fraud in Declaratory Judgment; Appraisal Is Premature Until Coverage and Timing of Loss Are Proven Introduction In Rhode Island Joint Reinsurance Association v....

Compelling Circumstances Permit Separation-Date Valuation of Marital Equity Awards; Unvested Stock/RSUs May Be Treated as Post-Separation Compensation

Date: Jul 24, 2026

Compelling Circumstances Permit Separation-Date Valuation of Marital Equity Awards; Unvested Stock/RSUs May Be Treated as Post-Separation Compensation Introduction In Patrick M. Hogan v. Amanda H....

Rule 11 and § 9-29-21 Sanctions in Divorce: Counsel Fees Without a Financial-Need Prerequisite

Date: Jul 20, 2026

Rule 11 and § 9-29-21 Sanctions in Divorce: Counsel Fees Without a Financial-Need Prerequisite Introduction In Cassandra Constantino v. Zsolt Orban (R.I. July 17, 2026), the Rhode Island Supreme...

Emergency-Aid Exigency “Evaporates” Once the Crisis Is Verified: No Warrantless Entry Into a Separate Apartment Absent Objective, Known Facts

Date: Jul 18, 2026

Emergency-Aid Exigency “Evaporates” Once the Crisis Is Verified: No Warrantless Entry Into a Separate Apartment Absent Objective, Known Facts 1. Introduction State v. Noel Ignacio Moronta (R.I. July...

Rule 804(b)(3) in Rhode Island: Self-Defense Framing Does Not Bar “Statement Against Interest” Admissibility When Reliability and Corroboration Support Trustworthiness

Date: Jul 18, 2026

Rule 804(b)(3) in Rhode Island: Self-Defense Framing Does Not Bar “Statement Against Interest” Admissibility When Reliability and Corroboration Support Trustworthiness 1. Introduction Terrel Barros...

State v. Quelon Page: Trial Justice Must Clearly Articulate “Thirteenth Juror” Weight-of-the-Evidence Reasoning When Denying a New Trial

Date: Jul 18, 2026

State v. Quelon Page: Trial Justice Must Clearly Articulate “Thirteenth Juror” Weight-of-the-Evidence Reasoning When Denying a New Trial 1. Introduction In State v. Quelon Page (R.I. July 16, 2026),...

Rhode Island Rejects “Language Conduit” Treatment for Unidentified Interpreters: Out-of-Court Interpreted Statements Are Hearsay Absent Reliability and Agency

Date: Jul 18, 2026

Rhode Island Rejects “Language Conduit” Treatment for Unidentified Interpreters: Out-of-Court Interpreted Statements Are Hearsay Absent Reliability and Agency I. Introduction In Galbin Fernandez, in...

Order Setting Rhode Island Zoning Certiorari for Full Briefing: Interpreting “Combining” in a Mixed-Use Planned Development Amendment and the Role of Former G.L. 1956 § 45-24-4.1

Date: Jul 16, 2026

Order Setting Rhode Island Zoning Certiorari for Full Briefing: Interpreting “Combining” in a Mixed-Use Planned Development Amendment and the Role of Former G.L. 1956 § 45-24-4.1 1. Introduction...

Lay Evidence of Loss of Use and Quiet Enjoyment Suffices for Irreparable Harm in Nuisance-Based Preliminary Injunctions; OSHA Reverse-Alarm Rule Does Not Preempt Local Noise Limits Where Dual Compliance Is Possible

Date: Jul 16, 2026

Lay Evidence of Loss of Use and Quiet Enjoyment Suffices for Irreparable Harm in Nuisance-Based Preliminary Injunctions; OSHA Reverse-Alarm Rule Does Not Preempt Local Noise Limits Where Dual...

Statute of Limitations Accrues on Nonpayment of Retirement Benefits Under a Nonmerged PSA; Court May Order a “Second” QDRO to Effectuate (Not Reform) the Agreement

Date: Jul 11, 2026

Statute of Limitations Accrues on Nonpayment of Retirement Benefits Under a Nonmerged PSA; Court May Order a “Second” QDRO to Effectuate (Not Reform) the Agreement 1. Introduction In Michele B....

State v. Porter (R.I. 2026): Trial Judges Must Make On-the-Record Findings at All Three Batson Steps; Omission of Step Three Requires Automatic Reversal

Date: Jul 11, 2026

State v. Porter (R.I. 2026): Trial Judges Must Make On-the-Record Findings at All Three Batson Steps; Omission of Step Three Requires Automatic Reversal Introduction State v. Leron Porter (Supreme...

Rule 60(b) as the Required Vehicle to Litigate Notice Defects After Conditional Default; Bonded Remand Authorized Under Appellate Rule 2

Date: Jul 9, 2026

Rule 60(b) as the Required Vehicle to Litigate Notice Defects After Conditional Default; Bonded Remand Authorized Under Appellate Rule 2 Case: Reagan Marine Construction, LLC v. Victor Costa et al....

State v. Juan Rivera — Rule 901 Authentication of Surveillance Video Through Digital-Forensics Testimony and Strict Raise-or-Waive Preservation

Date: Jul 4, 2026

Rule 901 Authentication of Surveillance Video Through Digital-Forensics Testimony and Strict Raise-or-Waive Preservation I. Introduction In State v. Juan Rivera (R.I. July 3, 2026), the Supreme Court...

RICRA Discrimination Claims Classified as “Actions of Tort” Under Rhode Island’s State Tort Claims Act

Date: Jul 4, 2026

RICRA Discrimination Claims Classified as “Actions of Tort” Under Rhode Island’s State Tort Claims Act 1. Introduction In Luther C. Parente v. Nelson Lefebvre, in his official capacity as Warden of...

Direct-Action Bar Reaffirmed: No Suit Against Auto Liability Insurer Without § 27-7-2 Exception; Bad-Faith Claims Require Contractual Entitlement

Date: Jul 4, 2026

Direct-Action Bar Reaffirmed: No Suit Against Auto Liability Insurer Without § 27-7-2 Exception; Bad-Faith Claims Require Contractual Entitlement Case: Bryan Edward Menge v. GEICO General Insurance...

Recusal in Rhode Island Family Court: Docket Management Delays and Adverse Rulings Do Not Establish Disqualifying Bias

Date: Jul 2, 2026

Recusal in Rhode Island Family Court: Docket Management Delays and Adverse Rulings Do Not Establish Disqualifying Bias Introduction In Kelly K. Fitzgerald v. James W.A. Jackson (R.I. June 25, 2026),...