Justia Rhode Island Supreme Court Opinion Summaries

After John and Anne had been married almost twenty years, John filed a complaint for divorce. Three years later, the parties indicated that they had reached a settlement, which obligated John to provide health insurance for Anne until she reached sixty-five years of age, with a Medicare supplement thereafter. The parties' agreement was read into the record and approved by the trial justice, who ordered it incorporated but not merged into the final divorce decree. However, the parties never executed a written agreement. John later challenged the validity of the marital settlement agreement after Anne moved to enforce the provisions of the agreement respecting John's obligation to pay for health insurance. The family court found that the parties clearly agreed that John was to cover Anne with her health insurance and ordered John to obtain and maintain the health insurance pursuant to the agreement. The Supreme Court affirmed, holding that the agreement was sufficient to form a nonmodifiable marital settlement agreement, and therefore, John was bound by its terms. View "O'Donnell v. O'Donnell" on Justia Law

Defendant's employer had insurance through American States Insurance Policy (ASIC). After Defendant was involved in a car accident, Defendant sent ASIC written notice of a potential claim under ASIC's uninsured/underinsured (UM/UIM) coverage. ASIC did not formally deny the claim but, rather, responded with a declaratory-judgment action, asserting that because Defendant had failed to undertake legal action or to make a written demand for arbitration against ASIC within three years from the date of the accident, her UIM claim against ASIC was time-barred. The U.S. district court entered judgment on the pleadings in favor of ASIC, determining that the three-year limitations period set forth in the policy did not violate public policy. On appeal, the court of appeals certified a question of law to the Rhode Island Supreme Court, which answered by holding that Rhode Island would not enforce the contractual limitations clause in this case because it began to run on the date of the accident rather than the date the insurance contract was breached and was shorter than the statutory limitations period. View "Am. States Ins. Co. v. LaFlam" on Justia Law

At issue in this appeal was the interpretation of a clause concerning the allocation of real estate taxes contained in a written lease between Inland American Retail Management and Cinemaworld of Florida. Inland and Cinemaworld were successors-in-interest to a ground lease for the rental of what is now a movie theater in a shopping center. Under the terms of the lease, Cinemaworld incurred certain liabilities and expenses. Pursuant to a clause in the lease, Cinemaworld was required to pay an amount equal to the real estate taxes "levied, assessed, or otherwise imposed" against the movie theater. Inland filed a complaint for breach of the lease for Cinemaworld's alleged failure to make timely payments as required by the lease. The superior court granted partial summary judgment in Cinemaworld's favor with respect to its motion seeking an accounting, ruling that the formula allocating Cinemaworld's reasonable share of real estate taxes should be based on the square footage of its leased premises. Inland appealed. The Supreme Court vacated the judgment of the superior court, holding that there was a genuine issue of material fact as to the interpretation of the parties' lease. View "Inland Am. Retail Mgmt. LLC v. Cinemaworld of Fla., Inc." on Justia Law

In 1995, Elizabeth Meyer, the sole shareholder and CEO of Greensleeves, Inc., orally agreed to buy six dock slips from Philip Smiley. Smiley subsequently entered into a purchase and sale agreement with Eugene Friedrich for the sale of those same dock slips. When Smiley refuse to convey the dock slips to Greensleeves, Greensleeves filed suit against Smiley. Friedrich intervened and moved to dismiss the complaint. The superior court granted judgment in favor of Smiley and Friedrich, finding no enforceable contract between Greensleeves and Smiley. The Supreme Court vacated the superior court's judgment, holding that there was an enforceable contract between Greensleeves and Smiley. Friedrich subsequently relinquished his ownership of the dock slips and conveyed them to Greensleeves. Greensleeves then sought an accounting of the rental income that had been collected from the dock slips from the date of the originally-scheduled closing between Greensleeves through the 1999 boating season. Ultimately, the trial court concluded (1) Friedrich had tortiously interfered with the contract between Smiley and Greensleeves, and (2) Greensleeves was entitled to lost rental profits of $61,258 plus interest and costs. The Supreme Court affirmed, holding that the trial court did not commit reversible error in its findings and judgment. View "Greensleeves, Inc. v. Smiley" on Justia Law

Plaintiffs filed a purchase and sales agreement agreeing to buy Defendant's property and deposited ten percent of the purchase price with Defendant's real estate agent until closing. Defendant signed the agreement but also made certain handwritten alterations to the contract. Plaintiffs filed a complaint against Defendant, alleging that Defendant's handwritten alterations were material changes that constituted a counter-offer, not an acceptance of Plaintiffs' offer to purchase the property. The jury found there was never a valid contract between the parties and Plaintiffs were entitled to the return of their deposit. The trial court added prejudgment interest to the judgment. Defendant filed a motion to alter or amend the judgment, arguing that Plaintiffs were not entitled to interest on their deposit. The trial court denied the motion. The Supreme Court vacated the award of prejudgment interest in this case, holding that Plaintiffs' deposit did not fall within the category of "pecuniary damages" under R.I. Gen. Laws 9-21-10(a), and therefore, Plaintiffs were not entitled to prejudgment interest. View "Andrews v. Plouff" on Justia Law

This case involved a mediated settlement agreement between two of the heirs of Alfredo and the executrix of his estate, Maria. The superior court ordered Plaintiffs, Lucilio and Patricia, to execute general releases and pay attorney's fees incurred by Maria in seeking to enforce the settlement agreement. Plaintiffs appealed, arguing that the superior court erred in ordering them to execute general releases with terms that were materially different from those contemplated during settlement negotiations, and in assessing attorney's fees. The Supreme Court vacated the judgment of the superior court, holding (1) the trial justice erred in ordering Plaintiffs to execute the general release where the general release's language exceeded the clear and unambiguous terms of the settlement agreement; and (2) the superior court erred in awarding attorney's fees to Defendant pursuant to R.I. Gen. Laws 9-1-45, as the statute's threshold requirement that the party to receive the attorney's fees award be the "prevailing party" had not been met. View "Furtado v. Goncalves" on Justia Law

After Defendant failed to repay a loan Plaintiff made to him in the amount of $8,500, Plaintiff filed a complaint against Defendant alleging breach of contract and breach of an implied-in-fact contract. Plaintiff later amended his complaint to include a claim for failure to repay based on book account. After a jury, the trial justice ordered Defendant to pay damages to Plaintiff in the amount of $8,500. Defendant appealed, contending that the trial justice erred in finding that Plaintiff was a credible witness and in failing to find that the transaction was void because Plaintiff had allegedly advanced the money to Defendant with the knowledge that it would be used for gambling. The Supreme Court affirmed, holding that the Court had no choice but to uphold the lower court's findings because the Court was not provided with a transcript of the trial below and therefore was unable to properly engage in a review of the trial justice's factual findings. View "Vogel v. Catala" on Justia Law

Mortgage Electronic Registration Systems, as nominee for two lenders (collectively, Plaintiffs), held mortgages on Lot 456. For the property owner's failure to pay his water bill, the Pawtucket Water Supply Board (PWSB) auctioned the lot. PWSB issued a deed conveying the title in the property to Amy Realty. Amy Realty subsequently discovered that the property PWSB had intended to auction had been mistakenly listed as Lot 486 on the tax sale notices and deed. Amy Realty then obtained a corrective deed from the PWSB conveying title to Lot 456. Amy Realty subsequently filed a petition to foreclose on Plaintiffs' rights of redemption in Lot 456. Plaintiffs filed this action seeking to vacate the final decree of disclosure, alleging that the corrective deed changing the lot number from 486 to 456 was invalid and this infirmity rendered the foreclosure decree void. The superior court granted summary judgment for Plaintiffs. The Supreme Court affirmed, holding (1) the corrective deed obtained in this case was null and void because it was not recorded within sixty days of the tax sale; and (2) the final foreclosure decree may be vacated because the tax sale was invalid. View "Mortgage Elec. Registration Sys., Inc. v. DePina" on Justia Law

Plaintiff borrowed $249,900 from Lehman Brothers Bank to finance the purchase of a home, and he signed an adjustable rate note that evidenced the debt. Plaintiff and his wife (Plaintiffs) then executed a mortgage on the property that secured the loan. Even though the note was made payable to the lender, the mortgage was granted to Mortgage Electronic Registration Systems, Inc. (MERS) as nominee for the lender and the lender's subject and assigns. Plaintiffs subsequently defaulted on the note, and MERS initiated foreclosure proceedings. Plaintiffs subsequently commenced an action seeking to prevent MERS from exercising the power of sale contained in the mortgage, arguing that only a mortgagee was permitted to exercise the power of sale and that MERS was merely a nominee-mortgagee without the authority to foreclose. The superior court denied Plaintiffs' request and entered judgment on behalf of Defendants. The Supreme Court affirmed, holding that MERS had both contractual and statutory authority to foreclose and exercise the power of sale. View "Bucci v. Lehman Bros. Bank, FSB" on Justia Law

Pearl Archambault died while in the care of Haven Health Center of Greenville (Haven Health) after a nurse mistakenly administered a lethal overdose of morphine. The administratrix of her estate, Plaintiff, filed a medical malpractice action against Haven Health. Health Haven subsequently filed for Chapter 11 bankruptcy. Thereafter, Plaintiff amended her complaint to add Columbia Casualty Company, the professional liability insurer of Health Haven, as a defendant and asserted two counts against Columbia directly based on R.I. Gen. Laws 27-7-2.4, which permits an injured party to proceed against an insurer when the insured has filed for bankruptcy. The superior court entered default judgment against Haven Health. The court then granted summary judgment in favor of Columbia. The Supreme Court reversed and remanded with instructions to enter judgment against Columbia, holding that the superior court erred in interpreting Rhode Island law and that the insurance contract between Columbia and Health Haven should be construed in Plaintiff's favor. View "Peloquin v. Haven Health Ctr. of Greenville, LLC" on Justia Law