Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court quashed the decision of the superior court granting Defendant's motion to compel production of a complete, unreacted copy of a settlement agreement between Plaintiffs and the former codefendants who settled Plaintiffs' claims, holding that the trial justice abused her discretion in granting Defendant's motion.In granting Defendant's motion to compel production, the trial justice concluded that the amount paid in accordance with the settlement agreement was not discoverable "pursuant to Rhode Island and federal law." When Plaintiffs failed to comply with the order the superior court granted Defendant's motion to dismiss. The Supreme Court quashed the decision below and remanded the case, holding that the trial justice abused her discretion in granting Defendant's motion to compel production of a complete, unreacted copy of the settlement agreement. View "Noonan v. Sambandam" on Justia Law

The Supreme Court vacated the judgment of the superior court granting Verizon New England Inc.'s motion to dismiss this complaint related to a billing dispute over a particular telephone service contract, holding that the hearing justice erred in granting Defendant's motion to dismiss, which had been converted sub silentio to a motion for summary judgment.Plaintiff filed a complaint against Verizon alleging false representation and breach of contract stemming from a billing dispute. Verizon filed a motion to dismiss under Sup. Ct. R. Civ. P. 12(b)(6). The hearing justice dismissed Plaintiff's complaint in its entirety with prejudice. The Supreme Court vacated the judgment below, holding that that issues of genuine material fact existed precluding summary judgment. View "Resmini v. Verizon New England Inc." on Justia Law

The Supreme Court vacated the judgment of Supreme Court in favor of Plaintiff Wilmington Savings Fund Society, FSB in this case involving a dispute over payments due under a promissory note relating to Defendants' mortgage, holding that summary judgment was improperly granted under the terms of this case.Plaintiff's predecessor filed a complaint against Defendants alleging breach of contract. The hearing justice granted summary judgment in favor of Plaintiff. Defendants appealed, arguing that the issue of whether Plaintiff complied with the note's notice provisions was a question of material fact precluding summary judgment. The Supreme Court vacated the judgment below, holding that Plaintiff's failure to send the notice of default to the property address referred to in the note was not in accordance with the terms of the note, and therefore, summary judgment should not have been granted. View "Wilmington Savings Fund Society, FSB v. Cavalloro" on Justia Law

In this dispute arising from an ill-fated attorney-client relationship the Supreme Court affirmed the judgment of the superior court grantinf Plaintiff's motion for summary judgment, holding that there was no error in the proceedings below.Plaintiff filed a complaint alleging breach of contract and seeking to recover almost $13,000 for unpaid services provided to Defendant and claiming that she was entitled to statutory interest, attorneys' fees, and costs of suit. The hearing justice granted Plaintiff's unopposed motion for summary judgment. The Supreme Court affirmed, holding that there was no disputed issue of material fact and that Defendant was liable for the outstanding balance due as payment for Plaintiff's services. View "Oliveira v. Levesque" on Justia Law

The Supreme Court affirmed the order of the superior court denying Petitioner's petition for a writ of mandamus and dismissing his complaint pursuant to Sup. Ct. R. Civ. P. 12(b)(1) and 12(b)(6), holding that the superior court did not err.Plaintiff, a former employee of the City of East Providence, attempted to rescind an agreement he made with the City regarding, among other things, his retirement benefits and the issuance of a corrected W-2 to reflect his injured-on-duty status. The trial judge entered judgment for the City. Plaintiff then filed a complaint and petition for a writ of mandamus against his union asking the superior court to abrogate agreement regarding the period of his injured-on-duty status. The trial court granted Defendants' motion to dismiss. The Supreme Court affirmed, holding (1) several of Plaintiff's arguments were waived; and (2) this case was barred by res judicata. View "Jenkins v. City of East Providence" on Justia Law

The Supreme Court vacated the judgment of the superior court entered favor of Allstate Property and Casualty Insurance Company in this breach of contract action, holding that, under the circumstances, the court erred in granting Allstate's motion for summary judgment.Plaintiff made a claim for loss under its homeowners policy with Allstate after a water loss Plaintiff's property suffered. While Plaintiff sought to invoke a provision in the policy that either party could seek appraisal in the event of a dispute as to the amount of the loss Allstate refused to proceed to appraisal. Plaintiff filed suit for breach of contract in his first action. Allstate counterclaimed seeking a declaration that the parties were required to submit the matter to appraisal. The trial justice granted summary judgment for Allstate without prejudice. Thereafter, Plaintiff demanded that Allstate move forward with the appraisal process. Allstate refused, asserting that Plaintiff's demand was untimely under the policy. Plaintiff then commenced the instant action seeking relief in the form of a judgment ordering Allstate to designate an appraiser and to complete the appraisal process. Final judgment entered for Allstate. The Supreme Court vacated the judgment below, holding that Plaintiff's initial demand for appraisal was not time-barred, and therefore, the trial court erroneously granted summary judgment for Allstate. View "Romeo v. Allstate Property & Casualty Insurance Co." on Justia Law

The Supreme Court affirmed the judgments of the superior court granting six motions for summary judgment in three underlying cases, holding that the motion justice did not err by ordering reformation of the warranty deeds of both Raymond Burt and Tammy Lacoste and the mortgage deed of Burt.The superior court's order of reformation was based on the uncontested facts that the warranty deeds and mortgage deed at issue did not reflect the parties' intent and the motion judge's conclusion that the deeds were the product of a mutual mistake. The Supreme Court affirmed, holding (1) uncontested evidence in the record clearly and convincingly demonstrated that the warranty deeds and mortgage deed failed correctly to express the parties' agreement and were thus the product of mutual mistake; and (2) summary judgment was properly granted with respect to each of the six motions for summary judgment. View "Burt v. Furtado" on Justia Law

The Supreme Court affirmed the order of the superior court denying Defendant's motion for a new trial after judgment entered in favor of Plaintiff, Ocean State Credit Union, in its action seeking money owed on a promissory note, holding that the trial justice did not overlook or misconceive material evidence and was not otherwise clearly wrong.Defendant entered into an agreement to repay a $3,000 loan that he had received from Plaintiff. Plaintiff later brought this action seeking $2,250 owed on the promissory note plus contractual interest. Final judgment entered in favor of Plaintiff. Thereafter, Defendant filed a motion for a new trial. When he learned the trial justice would hear the motion in Providence County instead of Kent County where the proceedings had previously been held, Defendant filed a motion to quash the change of venue. The trial justice denied relief. The Supreme Court affirmed, holding (1) the trial justice did not err in denying Defendant's motion for a new trial; and (2) Defendant's remaining contentions were without merit. View "Ocean State Credit Union v. Menge" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the superior court in favor of Defendant following the court's summary judgment and grant of motions to strike in favor of Defendant, holding that the hearing justice erred when he granted Defendant's motion for summary judgment as to count five of Plaintiff's complaint.Plaintiff filed a complaint alleging five counts against Defendant stemming from the purchase and lease of a commercial property. A hearing justice granted Defendants' motions to strike an expert disclosure and an affidavit. The Supreme Court vacated the judgment in part, holding that the hearing justice (1) properly granted Defendant's motion to strike the affidavit; but (2) erroneously granted summary judgment as to count five of the complaint. View "Donnelly Real Estate, LLC v. John Crane Inc." on Justia Law

Integra is an accountable-care organization under the Medicare Shared Savings Program (MSSP). RIPCPC is an independent practice association of physicians located in Rhode Island. The plaintiffs (Hayden, King, Corsi) are primary care physicians and operated their own independent practices. Each participated in Integra until 2018, when they terminated their respective agreements upon the sale of their respective independent practices (Integra agreements) and terminated their relationships with RIPCPC. The plaintiffs alleged breach of contract, unjust enrichment, breach of the implied covenant of good faith and fair dealing, conversion, and anticipatory breach/repudiation against Integra and RIPCPC, claiming that Integra and RIPCPC owed plaintiffs certain payments and shared savings for 2017 and 2018.The defendant’s motion to dismiss was granted as to breach of the implied covenant of good faith and fair dealing by RIPCPC and anticipatory breach/repudiation by RIPCPC. RIPCPC then successfully moved to stay the proceedings and compel arbitration as to plaintiffs’ claims against RIPCPC for breach of contract, unjust enrichment, conversion, and declaratory judgment. The Rhode Island Supreme Court held that the hearing justice did not err in granting RIPCPC’s motion to compel arbitration with regard to Hayden’s claims for breach of contract, conversion, and unjust enrichment nor in granting RIPCPC’s motion to compel arbitration with regard to Corsi’s claim for breach of contract but erred in granting RIPCPC’s motion to compel arbitration with regard to Corsi’s claims and King’s claims for conversion and unjust enrichment. View "Hayden v. Integra Community Care Network, LLC" on Justia Law