Ronald Rene Lagueux

In Hodge v. Murphy, a pro se pretrial detainee at the Wyatt Detention Facility sued the warden, health services director, and U.S. Marshals Service, alleging that officials missed doses of his migraine and back-pain medication, ran out of medication, gave doses to the wrong inmate, and kept inaccurate records, seeking an order for correct medication and damages. The court screened the complaint under 28 U.S.C. §§ 1915(e)(2) and 1915A and dismissed it for failure to state a claim. Treating the claims as arising under the Fourteenth Amendment Due Process Clause (with standards coextensive to the Eighth Amendment), the court found no plausible facts showing that defendants were deliberately indifferent to a serious medical need, as there were no allegations of subjective awareness and conscious disregard of a substantial risk of harm; claims against the Marshals were also dismissed for lack of any factual allegations against them.

civil rightscriminal lawhealthcare

The case involved Blue Cross suing two health care providers for breach of contract, fraud, defamation, and tortious interference, alleging they miscoded services under provider agreements to obtain over $400,000 in unauthorized payments from ERISA-governed health plans. Defendants removed the case to federal court, asserting complete preemption under ERISA, while Blue Cross moved to remand for lack of subject matter jurisdiction. The court rejected the magistrate judge's recommendation to remand, holding that federal jurisdiction existed because the state claims were completely preempted by ERISA and the counterclaims directly invoked ERISA provisions.

healthcarebusiness & regulatoryprocedure

This case involves an objection by Timesharing Associates, Ltd. (TSA) to a receiver's recommendation denying its equitable claim for over $723,000 against the receivership estate of Fairway Capital Corporation, an SBA-licensed entity tied to a complex series of transactions and foreclosures involving a Virgin Islands timeshare resort development dating back to the 1980s. The court adopted the receiver's recommendation and denied TSA's claim in full. The core reasoning was that, although TSA's claim could fall within the receivership's supplemental bar date for Fairway's alter egos, it was barred by laches due to TSA's unreasonable delay in asserting its interests after the 1996 foreclosure judgment and 2001 receivership proceedings, which caused prejudice to the SBA and other parties as the receivership neared its conclusion.

business & regulatoryprocedure

The case involved surviving family members of American citizen Yaron Ungar and his wife, who were murdered by Hamas terrorists in Israel in 1996, suing the Palestinian Authority, the Palestine Liberation Organization, and others under the federal Antiterrorism Act for damages. After years of litigation where the PA and PLO chose not to defend on the merits, a default judgment of over $116 million was entered against them. The defendants moved to vacate the judgment under Federal Rule of Civil Procedure 60(b)(6), arguing exceptional circumstances. The court denied the motion, reasoning that the defendants had made deliberate strategic choices not to participate fully, including instructions from their leader not to recognize the court's jurisdiction, and that litigation must eventually conclude.

proceduretorts & liability

This case involved a proposed class action lawsuit brought on behalf of approximately 3,000 children in the custody of Rhode Island's Department of Children, Youth and Families (DCYF), alleging that underfunding, understaffing, and mismanagement of the child welfare system violated the children's substantive and procedural due process rights under the Fourteenth Amendment, as well as rights under the federal Adoption Assistance Act and state law. The plaintiffs, represented by the state's Child Advocate and proposed "Next Friends," sought declaratory and injunctive relief for harms including unsafe foster placements and inadequate services. The court granted the defendants' motion to dismiss under Rule 12(b)(1), holding that the Child Advocate and Next Friends lacked standing and authority to sue because all named plaintiffs were already represented by court-appointed special advocates (CASA) attorneys appointed by the Rhode Island Family Court, which retains ongoing jurisdiction over the children. The core reasoning centered on Federal Rule of Civil Procedure 17, which prioritizes duly appointed representatives, and the principle that federal courts should not interfere with the Family Court's established role in child custody and welfare matters.

family lawcivil rightsprocedure

This case is an appeal from U.S. Bankruptcy Court orders in a proceeding involving the bankrupt estate of Arnold Kilberg, where the trustee sought to sell real property at 165 Angell Street in Providence, Rhode Island, that was co-owned as tenants in common by the estate (50%) and appellants 56 Associates and 57 Associates (25% each). The bankruptcy court authorized the trustee to sell the entire property, ordered the appellants to provide keys for access to prospective buyers, and awarded the trustee counsel fees for related litigation. The district court affirmed, finding that the statutory conditions under 11 U.S.C. § 363(h) were satisfied because partition in kind was impracticable, a sale of the estate's undivided interest would yield significantly less, the benefit to the estate outweighed any detriment to the co-owners, and the property was not a utility asset; it also upheld the fee award as within the court's equitable contempt powers under 11 U.S.C. § 105(a).

propertyprocedure

This case involves petitioner Nickoyan Wallace's amended motion under 28 U.S.C. § 2255 to vacate his conviction and sentence following a jury trial for armed robbery of a federally licensed firearms dealer, conspiracy, and related firearm charges. On remand from the First Circuit, which directed consideration of claims not previously addressed after partial relief on a sentencing issue, the district court evaluated multiple allegations of ineffective assistance of trial and appellate counsel, prosecutorial misconduct, and sentencing errors. The court applied standards from cases like Strickland v. Washington and Smith v. Robbins to assess whether counsel's performance was deficient and prejudicial, concluding that many claims were either procedurally defaulted, contradicted by the record, or lacked merit because they would not have succeeded on appeal or at trial. It denied relief on the remaining claims after analyzing the trial record, closing arguments, and prior appellate rulings.

criminal lawprocedure

This case involved franchise developers who had signed store development agreements with Dunkin' Donuts and later entered a settlement agreement to resolve disputes over opening new shops in Rhode Island; the plaintiffs sued for breach of the settlement agreement along with related claims. Defendants moved to dismiss three counts of the complaint and to strike the jury demand based on waiver clauses in the development agreements. The court denied the motion to dismiss the count for breach of the implied covenant of good faith and fair dealing, but granted dismissal of the Massachusetts G.L. c. 93A and tortious interference counts for failure to state a claim. It further denied the motion to strike the jury demand, holding that the waiver provisions in the earlier development agreements did not extend to the later settlement agreement given the differences in timing, purpose, and the adhesive nature of the original terms.

business & regulatoryproceduretorts & liability

This case is a contract dispute arising from the 2003 sale of real property at 10-12 Payne Road in Barrington, Rhode Island, where the purchase price included a $200,000 promissory note whose full payment was conditioned on the buyers obtaining a zoning variance to alter the nonconforming use of the lot containing two houses. The buyers applied for the variance after closing but it was not granted within the one-year period specified in Rider A to the purchase and sale agreement. After a bench trial, the court held that the buyers were obligated to pay only $100,000 plus interest under the Rider's terms because the variance condition was not satisfied, rather than the full $200,000 plus interest sought by the seller. The decision rested on the plain language of the Rider, which reduced the note amount and adjusted the purchase price to $1,325,000 if no variance was obtained despite the buyers' good-faith efforts, and on findings that the buyers had met their diligence obligations.

property

This case concerned whether plaintiffs NORAD and Michael Miranda could be held liable for a large default judgment obtained by defendant unions against a related company, NATCO, arising from a collective bargaining agreement dispute over unpaid wages, vacation pay, and liquidated damages after NATCO ceased operations. The unions had secured the judgment in Pennsylvania and sought to enforce it in Rhode Island against the plaintiffs under federal labor law doctrines of single employer and alter ego, as well as state corporate alter ego principles. The court granted summary judgment to the plaintiffs and denied the defendants' motion, declaring the Pennsylvania judgment unenforceable against NORAD and Miranda. The core reasoning was that the judgment improperly allowed liquidated damages to accumulate from roughly $27,000 to over $2 million without any statutory authority, exceeding the limits of proper post-judgment interest and rendering the award invalid even against NATCO.

labor & employment

The case involved claims by Ricardo Hopkins, an African-American father, and his minor children against Rhode Island DCYF employees stemming from a 2001 child abuse investigation initiated after a former foster child accused Hopkins of sexual abuse from 1988 to 1996, followed by inquiries into his use of physical discipline like a switch on his own children. Plaintiffs brought federal constitutional claims alleging racial discrimination and defective procedures, state common law tort claims, and sought injunctive relief to reform DCYF operations. The court granted defendants' motion for summary judgment on all counts, holding that the investigation was based on reasonable suspicion and therefore constitutional, which eliminated any basis for injunctive relief or other claims due to the absence of a constitutional violation.

civil rightsfamily lawcriminal law

This case involves motions by several inmates at Rhode Island's Adult Correctional Institutions to intervene in or join a class action lawsuit originally filed in 1974 and 1975, which alleged that prison conditions violated the Eighth Amendment's prohibition on cruel and unusual punishment as well as the Fourteenth Amendment's equal protection clause. The original litigation was resolved by a 1994 Settlement Agreement that led to dismissal of the case in 1995, with provisions that ended the court's jurisdiction and transferred oversight of certain issues like population capacity to a state task force. The court denied the motions, reasoning that the settlement and dismissal terms clearly terminated its authority to enforce the agreement or address ongoing complaints, so the inmates must pursue any claims through a new, independent civil action.

criminal lawcivil rightsprocedure

The case involved a federal prisoner's motion under 28 U.S.C. § 2255 to vacate his conviction and sentence for being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1). The petitioner argued that his trial counsel provided ineffective assistance by failing to investigate or raise an intoxication defense, which he claimed could have negated the element of knowing possession of the gun found in his car after a traffic stop and chase. The court denied the motion, holding that counsel's decision was reasonable because the government's evidence included proof of actual possession, the intoxication defense would not have been viable under the facts presented at the plea hearing, and pursuing it risked prejudicing the jury against the petitioner.

criminal lawgunsprocedure

In this case, crewmen who worked on two commercial fishing vessels sued the corporate owners for failing to provide required written wage agreements before voyages under 46 U.S.C. § 10601 and for related damages under § 11107, after a prior partial summary judgment (affirmed on appeal) established that the statutes applied and the owners' agreements were non-compliant. The court awarded damages to three plaintiffs by calculating the difference between their actual layshare payments and full shares for specific trips, plus 6% prejudgment interest from the suit filing dates, while dismissing the claims of the other two plaintiffs against the respective defendants. The reasoning centered on the factual record of each plaintiff's trips and payments, the traditional layshare system used in the industry, and the court's discretion in admiralty to set interest rates.

labor & employmentbusiness & regulatory

The case involved Karen Stamp's challenge to the denial of accidental death and dismemberment benefits under her late husband Stephen Stamp's employee welfare benefit plan after he died in a single-car crash. The court granted summary judgment to defendants MetLife and Exxon Mobil entities, denying the claim. The core reasoning was that the policies required the death to result from an accident, but the insured's blood alcohol level of 0.265% at the time of the crash established that intoxication caused the incident, rendering it non-accidental under the plan terms.

labor & employment

This case arose from a 1971 class action lawsuit by juvenile inmates at Rhode Island's Training School challenging conditions of confinement under 42 U.S.C. § 1983, which led to a 1973 Consent Decree overseen by a Special Master with ongoing attorneys' fees awarded to prevailing plaintiffs. After the ACLU joined as counsel, state officials stopped direct payment of fees citing Rhode Island Rules of Professional Conduct 5.4(a) and 7.2(c) and R.I. Gen. Laws § 11-27-3, which bar lawyers from sharing fees with nonlawyers or nonprofits. The ACLU moved to intervene and for court approval of fee payments held in escrow or withheld since 2004. The court granted both motions, holding that the state disciplinary rules and statutes do not bar disbursement of fees to the ACLU in this federal proceeding, as the court's inherent authority to supervise attorneys and award fees under federal law controls, and recent statutory exemptions for tax-exempt nonprofits apply.

civil rightsprocedure

This case involved a dispute between Independent Financial Services, Inc. (IFS) and CCI Group, Inc. (CCI) over a contract where IFS was to assist CCI in obtaining financing for a resort project. IFS claimed CCI breached the agreement by failing to pay a placement fee and issue equity after securing a loan commitment from Lauras Master Fund. The court ruled in favor of IFS on the breach of contract claim, awarding $504,000 in damages plus interest, calculated as 4% of the $5.1 million loan amount actually utilized and the value of 2% of CCI's stock, while dismissing the incidental tort claims. The reasoning centered on the contract terms specifying compensation based on the gross loan amount and equity, with the court determining that money damages were appropriate instead of specific performance for the stock issuance.

business & regulatory

This case involved a former employee who sought long-term disability benefits under an ERISA-governed insurance plan after suffering multiple accidents in 1999 that caused headaches, vision issues, leg weakness, and cognitive symptoms, preventing her return to work as an attorney. After state-law claims were preempted, the court addressed cross-motions for summary judgment on the ERISA benefits claim. The court granted the insurer's motion and denied the plaintiff's, holding that the denial of benefits was reasonable and supported by substantial evidence. The reasoning centered on medical records and neuropsychological evaluations from the elimination period showing intact cognitive function and no total disability from performing essential job duties, despite some subjective symptoms.

labor & employment

Veronica Ashley, a former housekeeper at a Rhode Island Fairfield Inn, filed a single-count complaint against Paramount Hotel Group and related defendants alleging employment discrimination based on race and color under the Rhode Island Fair Employment Practices Act. The defendants moved for summary judgment, and the court granted the motion after reviewing the record. The decision rested on the absence of evidence creating a genuine issue of material fact, including Ashley's failure to submit required statements of disputed facts, her admission that failing to change bed linens was a terminable offense which she committed at least twice, the lack of connection between alleged discriminatory comments and her termination, and the fact that the same manager who hired her two years earlier also terminated her. The court concluded that Ashley had not shown the employer's stated reasons were a pretext for prohibited discrimination.

labor & employmentcivil rights

The case involved several former or current employees of the City of Central Falls, Rhode Island, who sued the newly elected mayor, Charles D. Moreau, and associated defendants over employment actions taken after the 2003 mayoral election, including suspensions, terminations, and a computer search; the claims encompassed federal constitutional and statutory violations under 42 U.S.C. § 1983, state common law torts, and municipal charter provisions, primarily alleging political retaliation and other misconduct. The court granted summary judgment to the defendants on the majority of counts, including all federal claims except two specific § 1983 allegations, and on most state claims for two plaintiffs, while dismissing the remaining state claims of two other plaintiffs without prejudice for lack of pendent jurisdiction. A limited number of claims were permitted to proceed, specifically one First Amendment patronage claim and claims involving a Fourth Amendment search and state computer trespass law. The core reasoning focused on the absence of genuine issues of material fact supporting the dismissed claims under summary judgment standards, combined with determinations that pendent jurisdiction over certain state claims was no longer warranted after resolution of the federal issues.

civil rightselectionslabor & employmentprocedure