Vikash Patel v. Rasikbhai Patel

Syllabus

The defendants appealed from a judgment entered in the Superior Court after a jury found in favor of the plaintiffs, and from an order of the Superior Court denying their motion for a new trial. On appeal, the defendants contended that the trial justice erred in permitting consideration of prior oral agreements under the parol evidence rule, impermissibly allowed for enforcement of an illegal scheme, abused his discretion by admitting a recording they alleged was illegally made to impeach a witness's testimony, and erred in denying their motion for a new trial. The Supreme Court held that the trial justice did not err in denying the defendants' motion for a new trial because the trial justice performed a comprehensive review of the evidence and the credibility of the witnesses before providing his grounds for denial. Additionally, the Court determined that the defendants failed to preserve their first two arguments, regarding parol evidence and illegality, which in any event lacked merit. The Supreme Court also upheld the trial justice's determination that an audio recording was admissible for impeachment and its late provision by the plaintiffs did not constitute a discovery violation. Accordingly, the Court affirmed the judgment and order of the Superior Court.