Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the superior court denying Defendant's renewed motion for judgment as a matter of law or, in the alternative, a motion for a new trial, holding that the trial justice did not err in denying the motions.A dispute over certain real property resulted in litigation and a jury trial. Plaintiff bought an eight-count amended complaint against Defendant. The jury was instructed to consider only Plaintiff's promissory estoppel and unjust enrichment claims, and the jury rendered a verdict in favor of Plaintiff on those counts. The Supreme Court affirmed, holding that Defendant was not entitled to judgment as a matter of law or a new trial as to the promissory estoppel and unjust enrichment claims. View "Salvatore v. Palangio" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendants, the individual unit owners of the Goat Island South Condominium (GIS Condominium) and the Goat Island South Condominium Association, Inc. (GISCA), holding that there was no genuine issue of material fact remaining in this case.In his decision, the hearing justice concluded (1) Plaintiff, IDC Clambakes, Inc., had failed to demonstrate that it would be unjust for Defendants to receive any benefit or that it conferred a benefit upon Defendants; and (2) Clambakes' quasi-contract claims were barred by res judicata. The Supreme Court affirmed, holding that Defendants were entitled to judgment as a matter of law because it would be inequitable for Defendants to retain any benefit that may have been conferred on them by Clambakes. View "IDC Clambakes, Inc. v. Carney" on Justia Law

In this partition action, the Supreme Court vacated the judgment of the superior court ruling that Plaintiff's death terminated her interest in a joint tenancy, holding that R.I. Gen. Laws 34-15-12 abrogates the common law right of survivorship in a joint tenancy when an action for partition is pending.Plaintiff filed a partition action requesting that the superior court partition property she owned in a joint tenancy with Defendants. Defendants asserted counterclaims for unjust enrichment and breach of agreement. While the litigation was pending, Plaintiff died. Defendants moved to dismiss the partition action, asserting that Plaintiff's property interest had passed to the remaining joint tenants by operation of law upon Plaintiff's demise. The hearing justice granted the motion. The Supreme Court vacated the judgment, holding that Plaintiff's decease did not abate her action for partition, and therefore, the litigation remained pending. View "Butler v. Gavek" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendant and dismissing Plaintiffs' claim for breach of the implied warranty of habitability, holding that Plaintiffs' claim for breach of the implied warranty of habitability was time barred.Plaintiffs purchased a home from Defendant and received a warranty deed. Plaintiffs later brought this action alleging seven counts. The hearing justice granted summary judgment in favor of Defendant on all counts, determining that Plaintiffs' tort claims were barred by the statute of repose and that this Court's holding in Nichols v. R.R. Beaufort & Associates, Inc., 727 A.2d 174 (R.I. 1999), barred Plaintiffs' claim based on the implied warranty of habitability. The Supreme Court affirmed, holding (1) Nichols applies to original homeowners, and therefore, homeowners have a period of ten years following substantial completion of improvement to real property to discover a latent defect; and (2) Plaintiffs' claim for breach of the implied warranty of habitability in this case was time barred. View "Mondoux v. Vanghel" on Justia Law

The Supreme Court affirmed the judgment of the superior court against Plaintiff and in favor of Defendant with respect to claims for fraud, negligent misrepresentation, and unjust enrichment, holding that Plaintiff's appeal was not properly before the Court.Plaintiff's underlying claims seemed from a relationship between Plaintiff and Defendant. Plaintiff asserted that he and Defendant had committed to each other to be in a long-term relationship but that Defendant decided to end that relationship. Plaintiff argued that, but for Defendant's representation that they would remain together, Plaintiff would not have devoted his time, energy, and expertise to Defendant. The superior court granted summary judgment for Defendant on all counts. The Supreme Court affirmed, holding that Plaintiff's appeal was untimely. View "Paroskie v. Rhault" on Justia Law

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

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

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

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

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