The case involved Felipe Arias, who was charged with possessing a firearm as a felon in violation of 18 U.S.C. § 922(g)(1). Arias moved to suppress the firearm that police seized from the vehicle in which he was a passenger during a traffic stop in Providence. After an evidentiary hearing, the court granted the motion to suppress. The court reasoned that a traffic stop is a Fourth Amendment seizure requiring either reasonable suspicion of criminal activity or probable cause of a traffic violation, but the government failed to show that the officer had either, as the officer's account of the stop did not establish objective grounds and appeared pretextual.
This case involved consolidated actions by automobile manufacturers, manufacturers' associations, and Rhode Island dealers seeking a declaratory judgment that a Rhode Island regulation setting greenhouse gas emissions standards for new vehicles was invalid because it was preempted by the federal Energy Policy and Conservation Act and Clean Air Act. The Rhode Island Department of Environmental Management moved for judgment on the pleadings, arguing that the preemption claims were barred by issue preclusion due to prior rulings in similar cases from Vermont and California district courts. The court granted the motion as to the manufacturers and associations, finding that those parties had already litigated and lost the identical preemption issues in the earlier cases. However, the court denied the motion as to the dealers, holding that they were not parties to the prior litigation and that no exception for nonparty preclusion applied. The decision rested on principles of collateral estoppel, including the requirements of privity and adequate representation.
Gordon Ondis filed a qui tam lawsuit under the False Claims Act against the City of Woonsocket and its mayor, claiming they submitted false statements to HUD about supporting affordable housing in order to obtain federal grants. The defendants moved to dismiss for lack of subject matter jurisdiction, arguing the claims relied on information that had already been publicly disclosed. The court granted the motion after finding that nearly all the underlying incidents and statements had appeared in local newspapers or been revealed in a prior state court case. It further held that Ondis was not an original source because his knowledge came second-hand from employees who reviewed public records and interviewed others, without any direct or specialized insight that would qualify under the statute.
David Campbell, a former inmate at the privately operated Wyatt Detention Facility, sued under 42 U.S.C. § 1983 (treated as a Bivens action) alleging that the facility's refusal to provide a vegetarian diet required by his Rastafarian religious beliefs violated his First and Eighth Amendment rights, and that the destruction of his legal papers from pending lawsuits also violated his First Amendment rights. The parties filed cross-motions for summary judgment. The court denied Campbell's motion, granted the defendants' motion on the Eighth Amendment diet claim and the First Amendment claim regarding destruction of legal papers because no tangible injury resulted, and denied the defendants' motion on the First Amendment religious diet claim due to a genuine issue of material fact regarding the burden on Campbell's religious exercise. The ruling turned on whether the evidence showed a substantial burden on religious practice, deliberate indifference to serious medical needs, or actual harm from loss of documents in the underlying cases.
Legion Insurance brought a declaratory judgment action against its insured Family Service, Inc., seeking a ruling that its liability policy provided no coverage for an employment discrimination lawsuit filed by a former employee. After the parties entered a Global Settlement Agreement requiring Legion to contribute to the settlement and pay Family Service's defense costs, Legion failed to pay and later entered liquidation proceedings. Family Service counterclaimed against Legion for breach of the policy and settlement agreement and filed a third-party claim against the Rhode Island Insurers’ Insolvency Fund. The court granted Family Service summary judgment on its counterclaim, finding that the settlement agreement was binding under Rhode Island law based on confirming documents, and denied the Fund’s motion to dismiss, holding that the attorneys’ fees claim qualified as a covered claim under the state insolvency statute because it arose from the policy coverage.
Cynthia Dixon filed a putative class action against Calusa Investments alleging that the company violated the Fair Credit Reporting Act by obtaining her credit information without consent and mailing her solicitations for a debt consolidation loan that did not qualify as a 'firm offer of credit' under the statute. The mailers stated that any loan would depend on meeting pre-selection criteria and required collateral in the form of real estate but did not specify interest rates or other loan terms. The court granted Calusa's motion to dismiss, overruling Dixon's objections to the magistrate's recommendation. Relying on the First Circuit's intervening decision in Sullivan v. Greenwood Credit Union, the court held that a firm offer of credit under FCRA need not include additional material terms beyond the pre-selection criteria and that the mailers satisfied the statutory definition because credit would be extended if those criteria were met.
