DeOliveira v. Trecaso — Trial Court Affirmed on All Eleven Error Claims; Deposition of Dismissed Defendant, Google Earth Photos, and Verdict Sheet Phrasing Each Upheld
The Rhode Island Supreme Court affirmed a defense verdict in a motor vehicle negligence case, rejecting all eleven error claims by the plaintiffs. Significant holdings address: the admissibility of a dismissed defendant’s video deposition under Rule 32; authentication of bare Google Earth photographs by lay witnesses with personal knowledge; the narrow scope of the empty chair doctrine as limited to identifiable available witnesses; and the adequacy of a verdict sheet that used “was negligent” language in a comparative fault framework.