Justia Rhode Island Supreme Court Opinion SummariesArticles Posted in Contracts
Andrews v. Lombardi
In this action challenging an ordinance passed in 2011 requiring retirees from the City's police and fire departments to enroll in the federal Medicare program upon reaching the age of eligibility instead of continuing to have the City pay for their private health insurance for life the Supreme Court affirmed in part and vacated in part the final judgment of the superior court in favor of the City, holding that the trial judge misconceived the evidence with respect to the health care benefits that Plaintiffs were receiving from the City.Most police or firefighter retirees filed suit challenging the ordinance, and many settled. Some retirees opted out of the settlement and pursued their claims through a bench trial. The trial justice found in favor of the City. The Supreme Court held (1) with respect to Plaintiffs' claims for breach of contract, violation of the Takings Clause, and promissory estoppel, the superior court's judgment was proper; and (2) as to Plaintiffs' Contract Clause claims, the trial justice overlooked or misconceived evidence in several crucial respects. The Court remanded the case with instructions to enter judgment consistent with the provisions pertaining to the Medicare Ordinance as set forth in the final and consent judgment in the lawsuit from which Plaintiffs opted out. View "Andrews v. Lombardi" on Justia Law
Andrews v. Lombardi
In this case challenging the City of Providence's ordinance suspending annual cost-of-living-adjustments (COLAs) for retired members of its police and fire departments until the pension fund achieved a seventy percent funding level the Supreme Court affirmed in part, vacated in part, and reversed in part the trial court judgment in favor of the City, holding that the pension ordinance was unenforceable as to certain plaintiffs.After the City enacted its ordinance in retiree groups and union groups initiated litigation to bar enforcement of the ordinance. Most retirees entered into a settlement that ripened into a consent judgment. Several individuals who opted out of the settlement agreement brought this suit. The trial justice entered judgment for the City. The Supreme Court affirmed in part and vacated in part, holding (1) the superior court correctly entered summary judgment on Plaintiffs' claims under the Takings Clause and for promissory estoppel; (2) with respect to the plaintiffs who were also a party in prior litigation regarding their COLA benefits and who were included in an earlier consent judgment or individual settlement agreement, the pension ordinance was unenforceable; and (3) with respect to Plaintiffs' challenge to the pension ordinance based upon the Contract Clause, the judgment is vacated. View "Andrews v. Lombardi" on Justia Law
Nelson v. Allstate Insurance Co.
The Supreme Court affirmed the judgment of the superior court dismissing Plaintiff's breach of contract case against Defendant, her homeowner's insurance carrier, after a hearing justice granted Defendant's motion for summary judgment, holding that summary judgment was properly granted in this case.Plaintiff, who had a homeowner's insurance policy purchased from Defendant, sought coverage for damage done to her residence when her water heater leaked and flooded her basement. When Defendant declined coverage Plaintiff filed a complaint claiming breach of contract. Defendant field a motion for summary judgment, arguing that Plaintiff's breach of contract claim failed as a matter of law because, under the unambiguous language of the policy, the flooding caused by the defective water heater was not a loss covered by the policy. The hearing justice granted the motion for summary judgment. The Supreme Court affirmed, holding that the damage caused by Plaintiff's malfunctioning water heater was clearly not one of the hazards articulated in the policy language. View "Nelson v. Allstate Insurance Co." on Justia Law
NESC, Inc. v. Bacon Construction Co.
In this dispute between a general contractor, Bacon Construction Co., Inc., and a subcontractor, NESC, Inc., regarding an agreement to install flooring in a college dormitory the Supreme Court affirmed the judgment of the superior court in favor NESC and awarding NESC $125,733.67 in damages, holding the trial justice did not clearly err in denying Bacon's motion for a new trial, appropriately denied Bacon's request for a remittitur and properly denied NESC's cross appeal.NESC brought this suit alleging, inter alia, breach of contract and unjust enrichment. Bacon filed a counterclaim against NESC alleging breach of contract and negligence. The jury rendered a verdict in favor of NESC. On appeal, Bacon challenged the trial justice's decision denying Bacon's motion for a new trial and its alternative request for a remittitur. NESC cross appealed from the denial of its motion to amend and its motion to reconsider its motion to amend. The Supreme Court affirmed the judgment and orders of the superior court, holding that the court did not err. View "NESC, Inc. v. Bacon Construction Co." on Justia Law
Midland Funding LLC v. Raposo
The Supreme Court affirmed the judgments of the superior court granting summary judgment in favor of Plaintiff, Midland Funding, LLC, in these consolidated credit card debt collection appeals, holding that Defendant failed to set forth facts that established a genuine issue of material fact as to whether the credit card accounts were in fact her accounts.The complaints in this case sought to recover the unpaid balance due on two credit card accounts. The district court granted summary judgment for Plaintiff in both cases. On appeal, Defendant argued that there existed an issue of fact as to the ownership of the accounts. The Supreme Court affirmed, holding that the evidence was insufficient to give rise to a genuine issue of material fact. View "Midland Funding LLC v. Raposo" on Justia Law
E.W. Burman, Inc. v. Bradford Dyeing Ass’n, Inc.
In this breach of contract action the Supreme Court affirmed the judgment of the superior court in favor of Defendant, holding that the trial justice did not err in finding that no oral contract existed between the parties.Plaintiff filed a complaint alleging breach of contract, breach of implied contract, and that Defendant was liable under the theories of quasi-contract and promissory estoppel. The trial justice entered judgment in favor of Defendant, finding that no oral or implied-in-fact contract existed between the parties and that Defendant was not liable under the theories of quasi-contract or promissory estoppel. The Supreme Court affirmed, holding that the trial justice did not misconceive or overlook material evidence, did not make factual findings that were clearly wrong, or misapply the law when finding that no oral contract existed between the parties. View "E.W. Burman, Inc. v. Bradford Dyeing Ass'n, Inc." on Justia Law
Posted in: Contracts
Edward F. St. Onge v. USAA Federal Savings Bank
The Supreme Court affirmed the orders of the superior court dismissing Plaintiff's claims against Defendants, USAA Federal Savings Bank and Charles Baird, for lack of personal jurisdiction, holding that the trial justice was correct in finding that the superior court did not have personal jurisdiction over Defendants.This case stemmed from an alleged oral agreement between Plaintiff and Baird. Plaintiff was a resident of Rhode Island, and Baird was a resident of Florida. Plaintiff filed a complaint against both Baird and USAA, a bank incorporated and based in Texas with whom Baird maintained a personal checking account, seeking to recover certain funds plus consequential damages.The superior court dismissed the case against both defendants for lack of personal jurisdiction. The Supreme Court affirmed, holding (1) the superior court was correct in finding that it did not have either general personal jurisdiction or specific jurisdiction over USAA; and (2) the trial justice was correct in finding that the superior court did not have specific personal jurisdiction over Baird. View "Edward F. St. Onge v. USAA Federal Savings Bank" on Justia Law
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