Justia Rhode Island Supreme Court Opinion Summaries

Plaintiff-general contractor entered into an agreement with Defendant-subcontractor to perform work on a project. A dispute arose between the parties when Plaintiff issued Defendant a notice of termination. The issue was submitted to arbitration, and both parties submitted claims to the arbitrator for money damages. The arbitrator found that Plaintiff’s termination of Defendant was wrongful and granted damages. Plaintiff sought to vacate the arbitrator’s award. The trial court concluded that a release signed by Defendant that waived all claims prior to a certain date barred Defendant’s claims. The Supreme Court vacated the judgment of the superior court, holding that the arbitrator’s decision should have been allowed to stand because it showed due regard for the parties’ release and did not reach an irrational result. View "Berkshire Wilton Partners, LLC v. Bilray Demolition Co." on Justia Law

Plaintiffs agreed to lease medical diagnostic imaging equipments to Defendants for use in a medical imaging center. The center proved to be unsuccessful shortly after it opened, and Defendants defaulted on their payments. Plaintiffs filed a fourteen-count complaint against Defendants that included counts for replevin, breach of contract, breach of consent to sublease, and breach of sublease. Defendants counterclaimed for intentional misrepresentation, negligent misrepresentation, fraud and deceit, and a violation of Mass. Gen. Laws ch. 93A. The superior court granted summary judgment for Plaintiffs on all claims and counterclaims. The Supreme Court affirmed, holding that there were no genuine issues of material fact, and therefore, summary judgment was proper on Plaintiffs’ claims and Defendants’ counterclaims. View "Siemens Fin. Servs., Inc. v. Stonebridge Equip. Leasing, LLC " on Justia Law

At issue in this case was which party was entitled to insurance funds under an insurance policy on a parcel of property that sustained water damage. Stanley Gurnick and Phoenix-Gurnick, RIGP claimed they owned the property as a result of a foreclosure sale. Navigant Credit Union claimed it was entitled to the funds as the named mortgagee/loss payee in the insurance policy. The superior court decided that Navigant was entitled to the insurance proceeds because the funds were personal property under the insurance contract and Navigant was named a loss payee under that contract. The Supreme Court affirmed, holding that the hearing justice correctly determined that Navigant was entitled to the insurance proceeds. View "R.I. Joint Reinsurance Ass’n v. O’Sullivan" on Justia Law

Plaintiffs purchased a home that a pre-closing inspection revealed had corrosion on the oil heating system in the basement. Although the boiler and oil tank were replaced prior to the sale of the home, the oil feed line buried beneath the concrete floor in the basement was not replaced. After Plaintiffs discovered an oil leak at the feed line, they initiated claims under their homeowners’ insurance policy issued by Defendant. Defendant denied Plaintiffs’ claim. Plaintiffs filed a complaint against Defendant for breach of contract. The trial justice granted summary judgment in favor of Defendant, concluding that Plaintiffs’ claim was caused by gradual corrosion of an oil fuel feed line, not by a sudden or accidental loss, and the claim was therefore barred by the clear and unambiguous terms of the policy. The Supreme Court affirmed, holding that because the undisputed evidence indicated that the damage to Plaintiffs’ property was caused by corrosion, which was not covered by their insurance policy, there were no genuine issues of material fact, and Defendant was entitled to judgment as a matter of law. View "Nunez v. Merrimack Mut. Fire Ins. Co." on Justia Law

In 2005, the Rhode Island Department of Administration and the Rhode Island Department of Health (collectively, the State), selected Plaintiff as its livery service provider through a bidding process. Plaintiff and the State entered into a contract setting forth the terms of the parties’ agreement. In 2007, the State terminated Plaintiff’s contract for alleged violations of the terms of the bid award. Plaintiff filed suit, alleging that the State breached the contract by terminating the agreement in bad faith and without cause. Before trial, the trial justice granted the State’s motion in limine to prohibit Plaintiff from introducing evidence to suggest that the contract was an exclusive agreement between the State and Plaintiff. The trial justice subsequently found that the State lawfully terminated its contract with Plaintiff in good faith and did not breach the contract. The Supreme Court affirmed, holding that the trial justice did not err in finding that the contract was not exclusive and that the State’s unilateral termination of the contract upon a finding of unsatisfactory performance did not constitute a breach. View "JPL Livery Servs., Inc. v. R.I. Dep’t of Admin." on Justia Law

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