Justia Rhode Island Supreme Court Opinion Summaries

Plaintiff fell and was injured on a sidewalk in the City of Providence. Plaintiff filed suit against the City and the State, alleging that it negligently failed to maintain or repair the sidewalk. The City moved for summary judgment, alleging that it did not owe a duty to Plaintiff because the State was responsible for the maintenance and repair of the sidewalk. In response, the State argued that a genuine issue of material fact existed as to whether the State or the city bore responsibility to maintain the sidewalk. The trial court granted summary judgment in favor of the City. The Supreme Court affirmed, holding that because the State did not assert a cross-claim against City, it was not sufficiently aggrieved by the entry of summary judgment in favor of the City on Plaintiff's claim to appeal from the superior court's judgment. View "Lombardi v. City of Providence" on Justia Law

Plaintiff filed suit against Defendant, one of his former law partners, after that law practice was dissolved. Plaintiff's complaint alleged intentional interference with prospective contractual relations, defamation, and corporate opportunity doctrine. The trial justice entered judgment against Plaintiff , finding that the evidence was insufficient as a matter of law to prove damages arising from the alleged tortious conduct of Defendant. The court subsequently denied Plaintiff's motion for a new trial. The Supreme Court affirmed, holding that the trial justice did not err (1) in concluding that damages for loss of reputation in a claim for tortious interference with a contract must be properly quantified; (2) in finding that the term "smoking gun" was not slanderous per se; and (3) in failing to submit Plaintiff's claim of breach of fiduciary duty to the jury. View "Bossian v. Anderson" on Justia Law

Buyers purchased real estate and retained Attorneys in connection with their purchase. Buyers sued Attorneys, alleging that, due to Attorneys' negligence, they overpaid Seller by more than $1,700,000. Attorneys filed a motion for leave to file a third-party complaint naming Agents as third-party defendants, alleging that Agents had a fiduciary duty to both Seller and Buyers and that if Buyers were entitled to recover for their alleged damages, then Agents would be liable for all or part of Buyers' claims against Attorneys. The superior court granted the motion. A motion justice subsequently granted Agents' motions to dismiss the third-party complaint, finding that the third-party complaint failed to plead a duty owed by Agents to either Buyers or Attorneys. The Supreme Court disagreed and vacated the superior court's subsequent denial of Attorneys' second motion for leave to file a third-party complaint, holding that Attorneys' second proposed third-party complaint fell within the scope of R.I. R. Civ. P. 14, which governs impleader. View "Wampanoag Group, LLC v. Iacoi" on Justia Law

Plaintiff filed this negligence action against Defendant, a medical doctor, seeking damages for injuries she sustained after she fell on an entrance ramp to Defendant's podiatric officers during a winter storm. The superior court granted summary judgment for Defendant, concluding (1) there was no dispute that the storm on the day of Plaintiff's fall included snow; (2) Defendant was justified to wait until the storm ended before taking action to treat his office entrance; and (3) Defendant did not owe Plaintiff or other invitees a heightened duty of care. The Supreme Court vacated the lower court's judgment and remanded, holding (1) because the parties disagreed as to the extent of the storm on the day of Plaintiff's fall, additional factual findings were required to determine whether Defendant was under a duty to treat his entranceway before the storm had ended, and thus, the grant of summary judgment was improper; and (2) Defendant did not owe Plaintiff a heightened duty of care. View "Sullo v. Greenberg" 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

Plaintiff received a wound from a dog bite from a pit bull. Plaintiff filed suit against Defendant, the owner of the building where the dog bite occurred. The superior court granted summary judgment in favor of Defendant, finding that the dog bite at issue occurred within the enclosure of the owner or keeper of the dog. On appeal, Plaintiff argued that a genuine issue of material fact existed as to whether the second-floor apartment where the dog bite occurred was a separate enclosure for purposes of R.I. Gen. Laws 4-13-16. The Supreme Court vacated the judgment of the superior court, holding (1) absent an inquiry into whether the second-floor apartment was kept locked and whether Defendant was excluded from the premises, it was impossible to determine whether the second-floor apartment was a separate enclosure within Defendant's house; and (2) there was a disputed issue of material fact was to whether Defendant knew of or permitted the dog's presence on his premises. View "Carreiro v. Tobin" on Justia Law

The underlying litigation arose from a real estate dispute between Plaintiff and several neighbors of Plaintiff (collectively, Codefendants). Codefendants retained attorneys (Attorney Defendants) to represent them in the property dispute. Attorney Defendants filed a notice of intent on behalf of Codefendants asserting Codefendants' right to their own property. Plaintiff filed a complaint against Defendants and later amended his complaint setting forth claims against Attorney Defendants for slander and title and intentional interference with prospective advantage. The superior court granted summary judgment in favor of Attorney Defendants. The Supreme Court affirmed, holding (1) Plaintiff failed to establish an essential element of his claim of slander of title; and (2) the notice of intent could not be said to constitute an improper act of interference, and therefore, Attorney Defendants were entitled to summary judgment with respect to the intentional interference claim. View "Beauregard v. Gouin" on Justia Law

Plaintiff was injured in a motor-vehicle collision with an underinsured driver (Tortfeasor). Tortfeasor was insured by Progressive Insurance Company (Progressive). Progressive paid Plaintiff its policy limits of $25,000. Plaintiff then sought recovery for personal injuries pursuant to the uninsured/underinsured motorist provisions (UM/UIM coverage) of her policy with Encompass Insurance Company (Encompass). Arbitrators issued a total award of $172,750. Plaintiff sought confirmation of the arbitration award. Encompass objected, arguing that Plaintiff's UM/UIM policy provided $100,000 maximum coverage, that Encompass had paid the policy limits in accordance with the insurance contract, and that, under Rhode Island law, Plaintiff was not entitled to recover from Encompass in excess of her policy limits. The trial justice vacated the portion of the award in excess of the $100,000 policy limit and confirmed the remainder of the arbitration award. The Supreme Court vacated the order of the superior court and directed that the arbitration award be reinstated in its entirety, holding that the superior court was incorrect in its interpretation of the law, and no grounds for modification or vacation of the award existed. View "Wheeler v. Encompass Ins. Co." on Justia Law

Plaintiffs, Nelson and Elaine Cruz, filed a complaint against the car dealership where Nelson purchased his vehicle (Ricky Smith), alleging that while Nelson was cleaning the inside of his minivan, both front airbags unexpectedly deployed, injuring him. Plaintiffs' complaint alleged negligence, strict products liability, negligent misrepresentation, and res ipsa loquitur. In addition, Elaine sought damages for loss of consortium. The trial justice granted Ricky Smith's motion for summary judgment on all counts. The Supreme Court affirmed, holding that the hearing justice properly granted summary judgment in Ricky Smith's favor on Nelson's claims of negligence and misrepresentation, and consequently, Elaine was barred from recovering damages for loss of consortium. View "Cruz v. DaimlerChrysler Motors Corp." on Justia Law

After she slipped and fell on an icy surface, Plaintiff filed a complaint alleging negligence by Defendant in failing property to maintain its property. The trial court granted summary judgment in favor of Defendant, finding, among other things, that Defendant, a commercial lessor, did not have a duty of care to Plaintiff, an invitee of a tenant. The Supreme Court affirmed, holding (1) the trial justice did not err in finding that Defendant owed no duty of care to Plaintiff; and (2) Plaintiff's argument that the trial court erred in denying her request for a continuance to conduct further discovery was waived, and even if the issue not been waived, the trial justice did not abuse her discretion in declining to grant a continuance. View "Berard v. HCP, Inc." on Justia Law