Justia Rhode Island Supreme Court Opinion SummariesArticles Posted in Contracts
Hebert v. City of Woonsocket
The Supreme Court vacated the judgment of the superior court that granted a preliminary injunction in favor of Plaintiffs restraining the City of Woonsocket from changing the terms of Plaintiffs' retiree health insurance, holding that the City had the statutory authority to make changes to Plaintiffs' health care benefits. Plaintiffs, several retried Woonsocket police officers, brought this action against the City and the Woonsocket Budget Commission (the WBC). The superior court granted a preliminary injunction for Plaintiffs and reinstated Plaintiffs' previous postretirement health care benefits. The Supreme Court vacated the judgment, holding that the trial justice (1) did not err when he found that Plaintiffs had a vested contractual right to free lifetime health care benefits; (2) erred when he found that the WBC lacked statutory authority when it adopted the Retiree Resolutions that required Plaintiffs to contribute to their health care expenses; and (3) erred in finding that the WBC violated the Contract Clause of the Rhode Island Constitution when it required Plaintiffs to pay for their health insurance under a new uniform health care plan applicable to all retirees and employees. The Court remanded the case to the trial justice for additional findings. View "Hebert v. City of Woonsocket" on Justia Law
Heneault v. Lantini
The Supreme Court affirmed in part and vacated in part the superior court's denial of Defendants' motion for a new trial after a jury found in favor of Plaintiff on his complaint alleging conversion and breach of contract, holding that Defendants waived their economic loss doctrine argument and that the trial justice erred in awarding attorneys' fees to Plaintiff. Plaintiffs entered into a lease with Defendants to rent commercial property owned by Defendants. Plaintiff was unable to occupy the commercial premises before the lease period could begin, but Defendants refused to return the security deposit. Plaintiff filed this action, alleging and breach of contract and that the refusal to return the security deposit constituted a conversion of his property. A jury found that Defendants had converted Plaintiff's security deposit to their own use. Judgment entered awarding Plaintiff compensatory damages plus attorneys' fees. Plaintiffs appealed, arguing that the economic loss doctrine barred recovery under the conversion claim and that the trial justice erred in awarding attorneys' fees pursuant to R.I. Gen. Laws 9-1-45. The Supreme Court held (1) Defendants waived the economic loss doctrine argument and may not now revive the argument on appeal; and (2) section 9-1-45 cannot be the basis for an attorneys' fees award in this case. View "Heneault v. Lantini" on Justia Law
JHRW, LLC v. Seaport Studios, Inc.
The Supreme Court affirmed the order of the superior court granting summary judgment in favor of Plaintiff as to Plaintiff's claim seeking injunctive relief for Defendants' alleged trespass and permanently enjoining Defendant and its officers, customers, and employees from parking in parking spaces owned by Plaintiff, holding that the hearing justice did not err in granting summary judgment on this claim. This case centered around a dispute over parking spaces in the Watch Hill section of Westerly. In an earlier case, Defendants sued Plaintiff regarding the parking spaces. Plaintiff later brought this action. After a hearing justice granted summary judgment on its injunctive relief claim, Defendants appealed, arguing that the trial justice erred by failing to order that the dispute be arbitrated and granting Plaintiff injunctive relief based on res judicata and collateral estoppel. The Supreme Court affirmed, holding (1) Defendants waived their right to arbitration of the injunctive relief claim; and (2) there existed identity of issues between the first action and the current dispute. View "JHRW, LLC v. Seaport Studios, Inc." on Justia Law
Management Capital, LLC v. F.A.F., Inc.
The Supreme Court affirmed the superior court's judgment ruling in favor of Plaintiff, Management Capital, LLC, on its complaint filed after Defendant, F.A.F., Inc., maintained that a common stock warrant held by Management had no value, holding that the superior court did not err in its judgment. Specifically, the Court held that trial justice did not err when he (1) reformed certain dates in a stock warrant that he found were a result of mutual mistake; (2) determined that “funded debt” was an unambiguous term meaning “long-term debt”; (3) found that FAF repudiated its obligations under the stock warrant; (4) found that Management properly preserved its post-repudiation rights; (5) determined that Management proved its damages with reasonable certainty; and (6) determined that prejudgment interest accrued beginning on October 13, 2008. View "Management Capital, LLC v. F.A.F., Inc." on Justia Law
Voccola v. Stop & Shop Supermarket Co.
The Supreme Court vacated the judgments of the superior court granting summary judgment in favor of the defendant and the third-party defendant (collectively, Defendants) on Plaintiff's complaint alleging negligence for her injuries and the third-party complaint seeking to defend, indemnify, and hold the third-party defendant harmless for claims arising out of the third-party defendant's duty under Defendants' snow services agreement, holding that genuine issues of material fact existed precluding summary judgment. Specifically at issue before the trial justice was whether there were genuine issues of material fact as to the dangerous condition that caused Plaintiff's fall that would preclude summary judgment. The trial justice weighed the evidence before her at least twice during the summary judgment hearing. The Supreme Court vacated the superior court's judgments, holding that the trial justice improperly weighed the evidence before her at the summary judgment hearing. View "Voccola v. Stop & Shop Supermarket Co." on Justia Law
Cranston Police Retirees Action Committee v. City of Cranston
In this appeal concerned two City of Cranston ordinances that promulgated a ten-year suspension of the cost-of-living adjustment benefit for retirees of the Cranston Police Department and Cranston Fire Department who were enrolled in the City's pension plan the Supreme Court affirmed the judgment of the superior court finding in favor of Defendants, holding that the superior court did not err in its judgment. The Cranston Police Retirees Action Committee (Plaintiff) brought this action against the City, Mayor Allan Fung, and members of the Cranston City Council (collectively, Defendants) alleging claims ranging from constitutional violations to statutory infringements. A superior court justice found in favor of Defendants on all counts. The Supreme Court affirmed, holding that the superior court justice did not err by (1) finding that the ordinances did not violate the Contract Clauses of the United States and Rhode Island Constitutions; (2) applying the burden of proof in the Contract Clause analysis; (3) applying expert testimony; (4) granting summary judgment for the City as to Takings Clause, res judicata, and Rhode Island Open Meetings Act claims; and (5) ruling on an assortment of motions and in her findings of fact and conclusions of law. View "Cranston Police Retirees Action Committee v. City of Cranston" on Justia Law
Chariho Regional School District v. State
The Supreme Court vacated the order of the superior court granting Defendants' motion to dismiss Plaintiff's complaint alleging breach of contract and seeking a declaration that Defendants had breached an agreement, holding that it cannot be said that Plaintiff failed to state a claim for which relief may be granted. Plaintiff, Chariho Regional School District, sued Defendants, the Rhode Island Department of Education, the Rhode Island Department of Administration, the Rhode Island Council on Elementary and Secondary Education, and the former Commissioner of Education alleging that the state Defendants had breached paragraph 1(d) of an agreement to convey certain property to Plaintiff "provided that Chariho continues to provide career and technical programs to students" (the CTC transfer agreement). A hearing justice granted the state Defendants' motion to dismiss. The Supreme Court vacated the order, holding (1) Plaintiff adequately pled a breach of paragraph 1(d) of the CTC transfer agreement; and (2) the hearing justice erred in finding that termination of the contract, as provided for in paragraph 3(a) of the CTC transfer agreement, represented Plaintiff's sole remedy for the state Defendants' breach. View "Chariho Regional School District v. State" on Justia Law
Family Dollar Stores of Rhode Island, Inc. v. Araujo
The Supreme Court vacated the September 20, 2016 judgment of the superior court entering judgment against Family Dollar Stores of Rhode Island, Inc. and affirmed the November 9, 2016 order of the superior court granting Family Dollar's emergency motion for a thirty-day extension of time within which to file its notice of appeal, holding that the hearing justice erred in dismissing Family Dollar's declaratory judgment action. Family Dollar filed this action against Justin B. Araujo seeking a declaratory judgment that the parties had entered into an enforceable settlement agreement releasing Family Dollar from claims that Araujo asserted against it in his charge before the Rhode Island Commission for Human Rights and also alleging breach of contract. The Commission was added as an additional party to the case. The hearing justice granted Defendants' motions to dismiss on the basis that the proper forum for this action was before the Commission. Family Dollar later filed an emergency motion for a thirty-day time extension, which the hearing justice granted. The Supreme Court affirmed in part and vacated in part, holding (1) the hearing justice did not abuse his discretion in finding excusable neglect in this case; and (2) Family Dollar's declaratory judgment action may proceed in superior court on remand. View "Family Dollar Stores of Rhode Island, Inc. v. Araujo" on Justia Law
Sullivan v. Coventry Municipal Employees’ Retirement Plan
The Supreme Court affirmed the decision of the plan administrator denying Plaintiff pension benefits, holding that the superior court did not err in granting Defendants’ motion to dismiss for lack of subject-matter jurisdiction and in alternatively granting summary judgment in favor of Defendants. Plaintiff requested pension benefits but Defendants denied the request. Plaintiff then filed a complaint for breach of contract as well as seeking a declaratory judgment against Defendants. The hearing justice ultimately determined that the court lacked subject-matter jurisdiction over Plaintiff’s claim and granted Defendants’ motion for summary judgment. The Supreme Court affirmed the superior court’s judgment regarding its lack of subject matter jurisdiction and reinstated and granted Plaintiff’s previously-denied petition or writ of certiorari, consolidated that matter with the present appeal, and affirmed the decision of the plan administrator denying Plaintiff pension benefits, holding that the plan administrator’s decision was sufficiently supported by testimonial and other evidence that that it reached a reasonable conclusion. View "Sullivan v. Coventry Municipal Employees’ Retirement Plan" on Justia Law
Broccoli v. Manning
The Supreme Court affirmed the order of the superior court entering summary judgment in favor of Defendant on Plaintiff’s complaint alleging breach of contract and fraud, holding that the hearing justice correctly granted Defendant’s motion for summary judgment after concluding that Plaintiff’s complaint was barred by the relevant statute of limitations. In his complaint, Plaintiff argued that Defendant breached his fiduciary duty owed to Plaintiff. The hearing justice concluded that the complaint was subject to the three-year statute of limitations for legal malpractice contained within R.I. Gen. Laws 9-1-14.3 and concluded that Plaintiff’s cause of action was untimely. The Supreme Court affirmed, holding that Plaintiff’s complaint was time barred. View "Broccoli v. Manning" on Justia Law