Justia Rhode Island Supreme Court Opinion Summaries

Cashman Equipment Corporation, Inc. (Cashman) was contracted by Cardi Corporation, Inc. (Cardi) to construct marine cofferdams for the Sakonnet River Bridge project. Cashman then subcontracted Specialty Diving Services, Inc. (SDS) to perform underwater aspects of the cofferdam installation. Cardi identified deficiencies in the cofferdams and sought to hold Cashman responsible. Cashman believed it had fulfilled its contractual obligations and sued Cardi for breach of contract, unjust enrichment, and quantum meruit. Cardi counterclaimed, alleging deficiencies in Cashman's construction. Cashman later added SDS as a defendant, claiming breach of contract and seeking indemnity and contribution.The Superior Court denied SDS's motion for summary judgment, finding genuine disputes of material fact. The case proceeded to a jury-waived trial, after which SDS moved for judgment as a matter of law. The trial justice granted SDS's motion, finding Cashman failed to establish that SDS breached any obligations. SDS then moved for attorneys' fees, which the trial justice granted, finding Cashman's claims were unsupported by evidence and lacked justiciable issues of fact or law. The trial justice ordered mediation over attorneys' fees, resulting in a stipulated amount of $224,671.14, excluding prejudgment interest.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's amended judgment. The Supreme Court held that the trial justice did not err in granting judgment as a matter of law, as Cashman failed to provide specific evidence of justiciable issues of fact. The Court also upheld the award of attorneys' fees, finding no abuse of discretion. Additionally, the Court determined that the attorneys' fees were not barred by the Bankruptcy Code, as they arose post-confirmation and were not contingent claims. View "Cashman Equipment Corporation, Inc. v. Cardi Corporation, Inc." on Justia Law

The Supreme Court answered a question certified to it by the United States Bankruptcy Court for the District Court of Rhode Island by holding that R.I. Gen. Laws 9-26-4(11) permits a debtor to claim an exemption for an inherited Individual Retirement Annuity (IRA).Lynette Kapsinow filed a Chapter 7 bankruptcy petition seeking, under Rhode Island law, to exempt an inherited IRA pursuant to section 9-26-4(11). The inherited IRA was inherited by Kapsinow from her late mother. The bankruptcy court certified to the Supreme Court the question about the availability of an exemption in bankruptcy with respect to the inherited IRA. The Supreme Court answered that a debtor may claim an exemption in an inherited IRA, including one inherited from a non-spouse, pursuant to section 9-267-4(11). View "In re Kapsinow" on Justia Law

Plaintiff executed a promissory note secured by a mortgage on his property. After Plaintiff defaulted on the loan, foreclosure proceedings commenced. Plaintiff subsequently filed a Chapter 7 bankruptcy petition. Then then-holder of the mortgage sought relief from the automatic stay imposed by bankruptcy law. Relief from the stay was given in two bankruptcy cases filed by Plaintiff, the second of which was initiated after a foreclosure sale had been completed. Plaintiff then filed an action seeking a declaration that the foreclosure deed was void and that he owned the property in fee simple absolute. The superior court granted summary judgment against Plaintiff based on the doctrine of res judicata. The Supreme Court affirmed, holding that Plaintiff was precluded from raising issues regarding the foreclosure again in the superior court after the propriety of the foreclosure was examined by the bankruptcy court and the foreclosure sale was declared valid.View "Reynolds v. First NLC Fin. Servs., LLC" on Justia Law

DWS Properties (DWS) owned rental property. The sole member of DWS was Dustin Shore. After a pipe burst at the property causing substantial damage, Shore executed contracts with Performance Adjusting Public Insurance Adjusters (Performance) and Multi-State Restoration (Multi-State), in which Performance agreed to provide public adjusting service relative to the loss, and Multi-State agreed to perform emergency clean-up work at the property. Performance and Multi-State (Plaintiffs) were never paid for the services they provided, and after Shore filed for personal bankruptcy, Shore's debts to Plaintiffs were discharged. Plaintiffs subsequently filed suit against DWS, seeking damages for book account, breach of contract, quasi-contract, and unjust enrichment. DWS filed a motion to dismiss, which the hearing justice converted into a motion for summary judgment and granted, reasoning that Shore had signed the contracts in an individual capacity without making any reference to DWS. The Supreme Court vacated the judgment of the superior court and remanded, holding (1) summary judgment was inappropriate on Plaintiffs' contract claims; and (2) the fact that DWS was not explicitly named on the contracts did not entitle it to judgment as a matter of law on Plaintiffs' equitable claims. View "Multi-State Restoration, Inc. v. DWS Props., LLC" on Justia Law