Justia Rhode Island Supreme Court Opinion Summaries

In this appeal concerned two City of Cranston ordinances that promulgated a ten-year suspension of the cost-of-living adjustment benefit for retirees of the Cranston Police Department and Cranston Fire Department who were enrolled in the City's pension plan the Supreme Court affirmed the judgment of the superior court finding in favor of Defendants, holding that the superior court did not err in its judgment.The Cranston Police Retirees Action Committee (Plaintiff) brought this action against the City, Mayor Allan Fung, and members of the Cranston City Council (collectively, Defendants) alleging claims ranging from constitutional violations to statutory infringements. A superior court justice found in favor of Defendants on all counts. The Supreme Court affirmed, holding that the superior court justice did not err by (1) finding that the ordinances did not violate the Contract Clauses of the United States and Rhode Island Constitutions; (2) applying the burden of proof in the Contract Clause analysis; (3) applying expert testimony; (4) granting summary judgment for the City as to Takings Clause, res judicata, and Rhode Island Open Meetings Act claims; and (5) ruling on an assortment of motions and in her findings of fact and conclusions of law. View "Cranston Police Retirees Action Committee v. City of Cranston" on Justia Law

The Supreme Court vacated the order of the superior court granting Defendants' motion to dismiss Plaintiff's complaint alleging breach of contract and seeking a declaration that Defendants had breached an agreement, holding that it cannot be said that Plaintiff failed to state a claim for which relief may be granted.Plaintiff, Chariho Regional School District, sued Defendants, the Rhode Island Department of Education, the Rhode Island Department of Administration, the Rhode Island Council on Elementary and Secondary Education, and the former Commissioner of Education alleging that the state Defendants had breached paragraph 1(d) of an agreement to convey certain property to Plaintiff "provided that Chariho continues to provide career and technical programs to students" (the CTC transfer agreement). A hearing justice granted the state Defendants' motion to dismiss. The Supreme Court vacated the order, holding (1) Plaintiff adequately pled a breach of paragraph 1(d) of the CTC transfer agreement; and (2) the hearing justice erred in finding that termination of the contract, as provided for in paragraph 3(a) of the CTC transfer agreement, represented Plaintiff's sole remedy for the state Defendants' breach. View "Chariho Regional School District v. State" on Justia Law

The Supreme Court vacated the September 20, 2016 judgment of the superior court entering judgment against Family Dollar Stores of Rhode Island, Inc. and affirmed the November 9, 2016 order of the superior court granting Family Dollar's emergency motion for a thirty-day extension of time within which to file its notice of appeal, holding that the hearing justice erred in dismissing Family Dollar's declaratory judgment action.Family Dollar filed this action against Justin B. Araujo seeking a declaratory judgment that the parties had entered into an enforceable settlement agreement releasing Family Dollar from claims that Araujo asserted against it in his charge before the Rhode Island Commission for Human Rights and also alleging breach of contract. The Commission was added as an additional party to the case. The hearing justice granted Defendants' motions to dismiss on the basis that the proper forum for this action was before the Commission. Family Dollar later filed an emergency motion for a thirty-day time extension, which the hearing justice granted. The Supreme Court affirmed in part and vacated in part, holding (1) the hearing justice did not abuse his discretion in finding excusable neglect in this case; and (2) Family Dollar's declaratory judgment action may proceed in superior court on remand. View "Family Dollar Stores of Rhode Island, Inc. v. Araujo" on Justia Law

The Supreme Court affirmed the decision of the plan administrator denying Plaintiff pension benefits, holding that the superior court did not err in granting Defendants’ motion to dismiss for lack of subject-matter jurisdiction and in alternatively granting summary judgment in favor of Defendants.Plaintiff requested pension benefits but Defendants denied the request. Plaintiff then filed a complaint for breach of contract as well as seeking a declaratory judgment against Defendants. The hearing justice ultimately determined that the court lacked subject-matter jurisdiction over Plaintiff’s claim and granted Defendants’ motion for summary judgment. The Supreme Court affirmed the superior court’s judgment regarding its lack of subject matter jurisdiction and reinstated and granted Plaintiff’s previously-denied petition or writ of certiorari, consolidated that matter with the present appeal, and affirmed the decision of the plan administrator denying Plaintiff pension benefits, holding that the plan administrator’s decision was sufficiently supported by testimonial and other evidence that that it reached a reasonable conclusion. View "Sullivan v. Coventry Municipal Employees’ Retirement Plan" on Justia Law

The Supreme Court affirmed the order of the superior court entering summary judgment in favor of Defendant on Plaintiff’s complaint alleging breach of contract and fraud, holding that the hearing justice correctly granted Defendant’s motion for summary judgment after concluding that Plaintiff’s complaint was barred by the relevant statute of limitations.In his complaint, Plaintiff argued that Defendant breached his fiduciary duty owed to Plaintiff. The hearing justice concluded that the complaint was subject to the three-year statute of limitations for legal malpractice contained within R.I. Gen. Laws 9-1-14.3 and concluded that Plaintiff’s cause of action was untimely. The Supreme Court affirmed, holding that Plaintiff’s complaint was time barred. View "Broccoli v. Manning" on Justia Law

In this case arising from a dispute arising from the parties’ lease agreement, the Supreme Court vacated the order of the superior court denying Defendant’s motion to stay litigation in favor of arbitration, holding that the parties failed to resolve their dispute through amicable mutual discussions pursuant to an arbitration clause in their agreement, and therefore, their dispute was ripe for arbitration.Plaintiffs leased from Defendant a parcel of land for the purposing of building and maintaining a building. Construction was never commenced, and Plaintiffs demanded that Defendant restore the property to its former condition. Plaintiffs later filed a complaint seeking a declaratory judgment that Defendant was in breach of the lease. Defendant moved for a stay of litigation, arguing that the arbitration clause in the lease required that all disputes be resolved by arbitration. The hearing justice denied the motion, concluding that the lease’s arbitration clause applied only to disputes that did not involve an alleged breach of the lease. The Supreme Court disagreed, holding (1) the language of the agreement provided that alleged breaches of the lease were to be arbitrated provided that the parties attempted and failed to resolve those disputes through mutual discussions; and (2) because the parties attempted conciliation, their dispute was ripe for arbitration. View "Rhode Island Council on Postsecondary Education v. Hellenic Society Paideia - Rhode Island Chapter" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendant in this construction dispute, holding that summary judgment was appropriate.Plaintiff entered into a contract with a general contractor to construct a facility. The general contractor subcontracted the roofing installation to Defendant. When the roof began to leak, Plaintiff filed a complaint against the general contractor and Defendant, alleging breach of contract, breach of the implied warranty to construct in good and workmanlike manner, misrepresentation, and negligence. The superior court granted Defendant’s motion for summary judgment, holding that Plaintiff was only an incidental beneficiary, as opposed to an intended beneficiary, of the subcontract between Defendant and the general contractor. The Supreme Court affirmed, holding that the motion justice appropriately granted summary judgment in favor of Defendant on Plaintiff’s claims. View "Hexagon Holdings, Inc. v. Carlisle Syntec Inc." on Justia Law

The Supreme Court vacated the judgment of the superior court in favor of Rhode Island Resource Recovery Corporation (Resource Recovery) in the amount of $5,733,648.18, inclusive of interest, on Resource Recovery’s claims of professional malpractice and breach of contract, holding that the trial justice erred in failing to grant Restivo Monacelli LLP’s (Restivo) motion for judgment as a matter of law.Although Restivo raised numerous contentions as to alleged error by the trial justice, the Supreme Judicial Court on appeal focused its inquiry only on Restivo’s contention that the trial justice erred in denying its motion for judgment as a matter of law because expert testimony with respect to proximate cause was required but was not presented by Resource Recovery. The Supreme Judicial Court agreed with Restivo, holding that expert testimony on the issue of proximate cause was required in this case, and Resource Recovery did not provide the required expert testimony as to proximate cause. View "Rhode Island Resource Recovery Corp. v. Restivo Monacelli LLP" on Justia Law

In this property dispute, the Supreme Court affirmed the judgment of the superior court denying Plaintiffs’ claims in whole and denying Defendants’ request for attorneys’ fees.When Defendants fenced the confines of an easement that was created by a settlement agreement and consent order entered by the superior court, Plaintiffs filed suit claiming that Defendants’ actions frustrated what they contended was the intended purpose of the consent order. The trial justice denied relief as to all of Plaintiffs’ claims. At a subsequent hearing, the trial justice denied Defendants an award of attorneys’ fees. The Supreme Court affirmed, holding that there was no abuse of discretion in the trial justice’s rulings. View "Arnold v. Arnold" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying the motion brought by Plaintiff, SMS Financial XXV, LLC, for summary judgment and granting the cross-motion for summary judgment brought by Defendants, David Corsetti and 385 South Main Street, LLC, on Plaintiff’s suit alleging that Defendants breached the terms of a promissory note.In the cross-motion for summary judgment, Defendants asserted that Plaintiff was unable to enforce or collect upon the note because the note had been lost. The hearing justice granted Defendants’ cross-motion for summary judgment. The Supreme Court affirmed, holding (1) under the plain language of R.I. Gen. Laws 6A-3-309(a) Plaintiff was not entitled to enforce the note because the note was in the possession of the original holder of the note when it was lost, not Plaintiff, to whom the original holder assigned its interest; and (2) pursuant to the statute, Plaintiff was not entitled to enforce the note’s provision mandating that Defendants issue a replacement note. View "SMS Financial XXV, LLC v. Corsetti" on Justia Law