Justia Rhode Island Supreme Court Opinion Summaries

The arbitrator in this case did not manifestly disregard the law or the provisions of the employment agreement at issue when he awarded Defendant extended severance payments based on his finding that Defendant had been the subject of a “de facto termination.”Defendant, the former vice president and chief financial officer of CharterCAREHealth Partners (Plaintiff), invoked the “de facto termination” provision of the parties' employment agreement and requested extended severance, contending that he had suffered a material reduction in his duties and authorities as a result of change in “effective control.” Defendant’s request was denied based on the assessment that he had suffered no material reduction in duties. Defendant filed a demand for arbitration seeking to be awarded extended severance benefits pursuant to the de facto termination provision of the employment agreement. The arbitrator determined that Defendant was entitled to the eighteen-month severance proscribed in the agreement’s de facto termination clause. Plaintiff filed a petition to vacate the arbitration award. The superior court denied the motion to vacate and granted Defendant’ motion to confirm the arbitration award. The Supreme Court affirmed, holding that there was nothing in the record to support Plaintiff’s contention that the arbitrator exceeded his powers or manifestly disregarded the law or the contract. View "Prospect CharterCARE, LLC v. Conklin" on Justia Law

The Supreme Court vacated in part and affirmed in part the Supreme Court’s grant of summary judgment in favor of Defendants - the Town of Scituate and others - on Plaintiff’s claims alleging breach of a memorandum of understanding (MOU).Specifically, Plaintiff alleged promissory estoppel and breach of contract, breach of confidentiality, tortious interference with a contract, and fraudulent misrepresentation. The trial justice granted summary judgment for Defendants, finding, among other things, that the MOU was not a binding agreement. The Supreme Court vacated the portion of the judgment granting summary judgment on Plaintiff’s breach of contract claim and otherwise affirmed, holding that the facts presented established that a contract was formed. View "Coccoli v. Town of Scituate Town Council" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of the Dunn’s Corners Fire District on its complaint seeking a declaration that it was not obligated to provide fire protection services to certain property located in the Village of Bradford in the town of Westerly, Rhode Island.Dunn’s Corners was a party to a contract that required Westerly Ambulance Corps, also a defendant in this case, to dispatch Dunn’s Corners to sites and locations situated within the Bradford Fire District. The hearing justice granted Dunn’s Corners’ motion for summary judgment, finding that the subject property lay outside of the Bradford Fire District. The Supreme Court affirmed, holding (1) Appellant’s argument that a declaratory judgment should not have issued because the Bradford Fire District was not a party to the action lacked merit; and (2) because Appellant conceded at oral argument that the subject property was not currently situated within any fire district, Appellant’s second argument that there remained a genuine issue of material fact as to whether the property was located within the Bradford Fire District was without merit. View "Dunn’s Corners Fire District v. Westerly Ambulance Corps" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the superior court granting summary judgment for Defendant, Price Rite, on count one of Plaintiff’s complaint and also granting Defendant’s motion to dismiss the remaining four counts.Plaintiff slipped and fell on liquid in an aisle of a store owned by Defendant. Plaintiff’s amended complaint alleged negligence, breach of contract, mode of operation, failure to warn, and breach of the implied warranties of merchantability, fitness for use, and fitness for a particular purpose. The court granted summary judgment on the negligence count and dismissed the remaining counts. The Supreme Court vacated the judgment of the superior court granting summary judgment on Plaintiff’s negligence claim and affirmed the dismissal of the remaining counts, holding (1) Plaintiff satisfied her burden of producing competent evidence that proved the existence of a disputed issue of material fact with respect to Defendant’s safety procedures or lack thereof, (2) the trial judge impermissibly weighed the evidence in his decision granting summary judgment, and (3) there is no requirement at the summary judgment stage for a plaintiff to produce direct evidence of how long a spill has existed on a floor. View "Dent v. PRRC, Inc." on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of West Davisville Realty Co., LLC (West Davisville) holding David Paolo liable on a personal guaranty of a termination of lease agreement between West Davisville and Alpha Nutrition, Inc. (Alpha).West Davisville filed a complaint against Alpha and Paolo alleging breach of contract and unjust enrichment. The hearing justice granted West Davisville’s motion for summary judgment. The Supreme Court affirmed, holding (1) any attempt by Paolo to point to purported evidence that West Davisville fraudulently induced Paolo to personally guarantee the agreements was not relevant in this appeal; and (2) the personal guaranty was valid because the underlying termination agreement was supported by consideration. View "West Davisville Realty Co. v. Alpha Nutrition, Inc." on Justia Law

Plaintiffs claimed that the sale of property without their consent to an entity of which Defendants were principals, was fraudulent. Plaintiffs also named as a defendant the title insurance and escrow agent in connection with the sale of the property. The superior court granted summary judgment in favor of all defendants. The Supreme Court affirmed the judgment in part and vacated it in part, holding (1) the hearing justice erred in determining that there was no factual issue regarding damages, and summary judgment is vacated as to the individual defendants to the extent that Plaintiffs may show damages for lost profits sustained in their individual capacities only; (2) the superior court properly granted summary judgment for the individual defendants as to Plaintiffs’ tortious interference with a contractual relationship claims, intentional interference with prospective contractual relations claims, breach of contract claims, fraud claims, and civil conspiracy claims; and (3) the judgment is affirmed in favor of the title company in all respects. View "Fogarty v. Palumbo" on Justia Law

In this commercial property dispute between a landlord, Roadepot, LLC and Keyserton, LLC (collectively, Roadepot), and a tenant, Home Depot, U.S.A., Inc., regarding sewer assessment charges, the Supreme Court affirmed in part and vacated in part judgments of the superior court. The Supreme Court held that the superior court (1) properly granted partial summary judgment in favor of Home Depot obligating Roadepot to pay the disputed sewer assessment charges; (2) the superior court erred in requiring Roadepot to reimburse Home Depot for sewer assessment charges paid by Home Depot before September 17, 2009; and (3) did not err in limiting Home Depot’s request for prejudgment interest and denying its claim for late fees on the sewer assessment charges. View "Roadepot, LLC et al. v. Home Depot, U.S.A., Inc." on Justia Law

This lawsuit arose from a dispute over an alleged commercial lease agreement between Plaintiffs, owners of certain property, and Defendants, who Plaintiffs claimed breached the terms of the lease. The superior court granted summary judgment in favor of Defendants, finding no genuine issues of material fact. The Supreme Court vacated the judgment of the superior court, holding that genuine issues of material fact existed in connection with two factual issues, and because of the fact-intensive nature of both of these inquiries, the case was not suitable for summary judgment and should, instead, have been resolved after a trial on the merits. View "Albert J. Branch Revocable Trust v. Interstate Battery Center" on Justia Law

Some four years after Plaintiff suffered a casualty loss to his property, Plaintiff sued Nationwide Mutual Fire Insurance Company (Defendant), which insured the property pursuant to a policy that it had issued to Plaintiff, alleging breach of contract and bad faith. Defendant moved for judgment on the pleadings, arguing that the claim must fail because Plaintiff did not fully comply with the provisions of the policy and because Plaintiff brought suit more than two years after the date of loss, in contravention of the terms of the insurance contract. The hearing justice granted Defendant’s motion for judgment on the pleadings. The Supreme Court affirmed, holding that because Plaintiff failed to adhere to the two-year limitation provision, Plaintiff was not entitled to relief. View "Chase v. Nationwide Mutual Fire Insurance Co." on Justia Law

The Supreme Court affirmed the trial justice’s determination that Plaintiff’s reappointment to his fourth consecutive two-year term as assistant zoning inspector in the Town of North Smithfield did not constitute a contract of employment. Plaintiff filed a complaint alleging breach of employment contract and a violation of his constitutional rights after his employment was terminated for budgetary reasons. The trial court entered final judgment in favor of Defendants. The Supreme Court affirmed the trial justice’s decision, holding that Plaintiff failed to produce sufficient evidence to support his contention that a valid contract existed. View "Andoscia v. Town of North Smithfield" on Justia Law