Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court held that the term "civil action" in Mass. Gen. Laws 27-7-2.2 refers to a judicial proceeding that is commenced by the filing in court of a complaint and all other required documents together with fees.This case involved an accident in which Horace Johnson and Carlton Johnson were seriously injured when Horace was driving. Before any party filed suit, Carlton's counsel sent a letter to Arbella Mutual Insurance Company, which had issued an automobile insurance policy to Horace, demanding a settlement in the amount of the $100,000 policy limit. After Arbella indicated its acceptance of the settlement offer Carlton and his mother (together, Plaintiffs) filed suit. The case was removed to federal district court, which granted summary judgment to Defendants, rejecting Carlton's argument that section 27-7-2.2 applied to the case and rendered Arbella's acceptance of the settlement offer ineffective. On appeal, the First Circuit Court of Appeals certified the instant question to the Supreme Court. The Supreme Court answered that "civil action" in section 27-7-2.2 refers to a judicial proceeding which is commenced by the filing of a complaint and all other required documents together with the fees prescribed by law. View "Johnson v. Johnson" on Justia Law

The Supreme Court affirmed the order of the superior court denying Defendant's motion to vacate entry of default, holding that the hearing justice did not abuse her discretion in denying Defendant's motion.Plaintiff was injured in a motorcycle accident. Plaintiff brought this complaint against Defendant alleging that he was insured by virtue of his contract with Defendant and that the denial of his uninsured motorist claims was unreasonable and made in bad faith. When Defendant failed timely to answer the complaint, default entered against Defendant. Defendant moved to vacate default, arguing that it had never been Plaintiff's insurer. The hearing justice denied the motion, finding that Defendant had not met the applicable standards to vacate default under Rule 55(c) of the Superior Court Rules of Civil Procedure. The Supreme Court affirmed, holding that Defendant failed to show good cause to excuse its failure to plead or defend. View "Ferris v. Progressive Casualty Insurance Co." on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment to Defendant, Narragansett Bay Insurance Company (NBIC), in this dispute as to whether Plaintiffs, pursuant to their homeowners insurance policy with NBIC, were entitled to receive a subsequent appraisal of the damage to their property as well as additional compensation for damage incurred, holding that the superior court did not err.Plaintiffs' home, which was insured by NBIC, received water damage stemming from the accumulation of snow on their roof. Plaintiffs submitted a claim to NBIC and received, in return, a check for $14,550. After depositing the check, Plaintiffs later filed a complaint alleging that NBIC had failed to abide by the terms of the homeowners insurance policy and seeking damages for the water damage. The superior court entered summary judgment in favor of NBIC. At issue on appeal was wether Plaintiffs, pursuant to their policy, were entitled to receive a subsequent appraisal of the property damage, along with additional compensation for damage incurred. The Supreme Court affirmed, holding that Plaintiffs' delay in requesting an appraisal was unreasonable, thereby relieving NBIC of its responsibilities under the insurance policy. View "Machado v. Narragansett Bay Insurance Co." on Justia Law

The Supreme Court vacated the order of the superior court granting summary judgment in favor of Liberty Mutual Insurance Company, holding that the trial justice did not err in holding that the statute of limitations barred Plaintiff's claim for personal injuries that arose from a fall on the property of Liberty Mutual's insured.In a second complaint, Plaintiff alleged that he slipped and fell at a Pizza Hut restaurant that was owned and operated by Mita Enterprises, LLC. Plaintiff then moved to substitute Liberty Mutual as a defendant. The motion was granted. Thereafter, Liberty Mutual moved to dismiss the amended complaint, arguing that the three-year statute of limitations barred Plaintiff's action. The trial justice agreed and granted summary judgment for Liberty Mutual. The Supreme Court vacated the superior court's judgment, holding that the trial justice erred in holding that the savings statute did not apply to Plaintiff's claim against Liberty Mutual. View "Frazier v. Liberty Mutual Insurance Co." 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

The Supreme Court vacated the judgment of the superior court that granted a preliminary injunction in favor of Plaintiffs restraining the City of Woonsocket from changing the terms of Plaintiffs' retiree health insurance, holding that the City had the statutory authority to make changes to Plaintiffs' health care benefits.Plaintiffs, several retried Woonsocket police officers, brought this action against the City and the Woonsocket Budget Commission (the WBC). The superior court granted a preliminary injunction for Plaintiffs and reinstated Plaintiffs' previous postretirement health care benefits. The Supreme Court vacated the judgment, holding that the trial justice (1) did not err when he found that Plaintiffs had a vested contractual right to free lifetime health care benefits; (2) erred when he found that the WBC lacked statutory authority when it adopted the Retiree Resolutions that required Plaintiffs to contribute to their health care expenses; and (3) erred in finding that the WBC violated the Contract Clause of the Rhode Island Constitution when it required Plaintiffs to pay for their health insurance under a new uniform health care plan applicable to all retirees and employees. The Court remanded the case to the trial justice for additional findings. View "Hebert v. City of Woonsocket" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Insurer and Plaintiff's claims alleging that Insurer was contractually obligated to provide insurance coverage to Plaintiff, which was listed as an additional issued on the relevant insurance policy, holding that Insurer had no duty to defend Plaintiff.Plaintiff, the general contractor for a construction project, subcontracted with Insured for structural work on the project. Insured purchased a commercial general liability insurance policy from Insurer, which named Plaintiff as an additional insured. The policy provided for defense and indemnification costs to Insured for its work on the project. Insured's employee (Employee), who sustained injuries while working on the construction project site, filed a complaint against Plaintiff, alleging that Plaintiff's negligent acts were the proximate cause of his injuries. Plaintiff sought a declaratory judgment that Insurer was contractually obligated to indemnify and defend Plaintiff as an additional insured relative to the Employee action. The superior court justice granted summary judgment for Insurer. The Supreme Court affirmed, holding that Employee's complaint was devoid of any allegations that brought the underlying case within the coverage of the policy, and therefore, Insurer had no duty to defend Plaintiff. View "Bacon Construction Co. v. Arbella Protection Insurance Co." on Justia Law

The Supreme Court affirmed the trial justice's judgment in favor of Summit Insurance Company in this declaratory judgment action seeking to clarify Summit’s liability for prejudgment interest and damages above the policy limits set forth in Summit’s automobile insurance contract with its insured, Eric Stricklett, holding that Summit owed no duty to Scott, John, and Cathy Alves.A car operated by Stricklett struck and injured Scott Alves. Stricklett’s vehicle was insured by Summit under a policy with a $25,000 per person, $50,000 per accident coverage limit. The Alveses sent Scott’s hospital bills to Summit, but Summit informed the Alveses that it had determined that Stricklett was not at fault for Scott’s injuries. The Alveses later made a settlement demand of $300,000 to Summit. Summit offered its policy limits on behalf of Stricklett, but the Alveses rejected the offer. Summit then filed this action requesting that the court determine whether Summit had an obligation to pay any sums beyond its policy limits. The trial justice granted judgment in favor of Summit. The Supreme Court affirmed, holding that the duty of an insurer to affirmatively settle an insurance claim on behalf of its insured does not apply with equal force to third-party claimants in the form of a duty of good faith and fair dealing. View "Summit Insurance Co. v. Stricklett" on Justia Law

Plaintiff, who was injured while rendering roadside aid as a Good Samaritan, was “occupying” the insured vehicle for purposes of underinsured motorist (UM) coverage and was therefore entitled to recover under the terms of a GEICO Insurance Agency, Inc. policy.Plaintiff was a passenger in a Saab driven by Gregory Hurst when the two witnessed an automobile collision. Plaintiff exited the Saab and was attempting to render assistance when she was struck by another car. Plaintiff settled a claim against the driver of the vehicle that hit her but claimed that she was not fully compensated for her injuries. Consequently, Plaintiff filed a claim with GEICO (Defendant) seeking relief through Hurst’s GEICO policy that insured the Saab. Defendant denied the claim on the ground that Plaintiff was not “occupying” the insured vehicle at the time of her injuries. Plaintiff then filed this action. The trial justice agreed with Defendant, concluding that Plaintiff could not recover UM benefits under the terms of the GEICO policy. The Supreme Court vacated the judgment of the superior court, holding that Plaintiff was entitled to recover under the terms of the policy. View "Hudson v. GEICO Insurance Agency, Inc." 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