Justia Rhode Island Supreme Court Opinion Summaries

Plaintiffs, David Miller and Miller’s Auto Body, alleged that they were subject to a malicious investigation into suspected insurance fraud that Defendants, three insurance companies, believed was taking place at Plaintiffs’ auto-body shop. Miller was charged with, among other charges, four counts of insurance fraud. The criminal information was dismissed by the Attorney General, but the dismissal was conditioned on an agreement between Miller and the Attorney General requiring Miller to execute a general liability release in favor of Defendants. More than one year after executing the release, Plaintiffs filed a complaint against Defendants. The trial court granted pretrial summary judgment for Defendants on the majority of Plaintiffs’ claims. Only Plaintiffs’ abuse-of-process claim went to trial. The jury returned verdicts in favor of Plaintiff against the two remaining defendants. The trial court subsequently granted judgment as a matter of law in favor of one defendant but denied the other defendant’s motion for judgment as a matter of law. The Supreme Court affirmed in part and reversed in part, holding that the release executed by Miller before he initiated suit barred all his claims against the defendants. View "Miller v. Metro. Prop. & Cas. Ins. Co." on Justia Law

One evening, Shawn McKiernan drove by Kevin Hough several times in an automobile owned by Rita Bower and taunted Hough as he drove past. McKiernan subsequently exited the insured vehicle and punched Hough, who was knocked to the pavement. Hough suffered a serious head injury as a result of the assault and battery. Hough filed a negligence complaint against Bower as the vehicle owner, alleging liability under the provisions of R.I. Gen. Laws 31-33-6, which imputes vicarious liability upon the owner of a vehicle for its consensual use or operation. Due to the subsequent death of Bower, Quincy Mutual Fire Insurance Company, the insurer of the vehicle, was substituted as a party defendant. The trial justice granted judgment as a matter of law in favor of Quincy. The Supreme Court affirmed, holding that Plaintiff failed to establish the causal relationship between the use of the vehicle and the injuries sustained by Plaintiff required to impute liability under section 31-33-6. View "Hough v. McKiernan" on Justia Law

Plaintiff was seriously injured in a collision while he was a passenger in a motor vehicle owned by the insureds of Defendant. Defendant obtained a judgment for money damages but subsequently settled with the insureds in exchange for an assignment of claims the insureds had against Defendant. Plaintiff then filed this action seeking a declaratory judgment requiring Defendant to pay the entire judgment from the underlying tort action (count one) and a declaration that Defendant was liable for prejudgment interest on the judgment in the underlying tort action (count two). A superior court justice granted summary judgment for Plaintiff on counts one and two. The Supreme Court vacated the judgment in count one and remanded for a new trial and affirmed the judgment in count two. On remand, Plaintiff sought a calculation of prejudgment interest. The superior court granted the motion, determining that Defendant’s argument with respect to the judgment satisfied order had been waived in regards to count two. The court subsequently ordered Defendant to make payment to Plaintiff. Defendant appealed from that order. The Supreme Court affirmed, holding that Defendant waived its arguments with respect to the judgment satisfied order and that the superior court had subject matter jurisdiction over the dispute throughout the litigation. View "DeMarco v. Travelers Ins. Co." on Justia Law

Quest Diagnostics, LLC was an independent contractor for Brown University under an agreement that obligated both parties to name the other party as an additional insured under their general liability policies. In 2006, Pauline Hall, a student at Brown University, sought treatment at the university’s health services clinic. A rapid strep test, to be performed by Quest, was ordered. The test, however, was not performed promptly, and the results were not returned to the health clinic. Hall was subsequently diagnosed with toxic shock syndrome, which resulted in permanent injuries. Hall filed suit against Brown and Quest, and Brown filed a cross-claim against Quest. Hall settled her claims with Brown and its insurers, Pinnacle Consortium of Higher Education and Genesis Insurance Company, but the cross-claim was not resolved. Quest subsequently sought a declaratory judgment that it was entitled to a defense from Pinnacle and indemnification from Pinnacle and Genesis. The superior court granted summary judgment in favor of Pinnacle and Genesis. The Supreme Court affirmed, holding that, under the facts of this case, Quest was not entitled to defense and indemnification from either insurer. View "Quest Diagnostics, LLC v. Pinnacle Consortium of Higher Educ." on Justia Law

After Plaintiff filed a complaint for divorce from Dean Miller, Plaintiff and Dean executed a property settlement agreement providing that Dean would maintain life insurance for the benefit of the parties' four minor children until they reached the age of majority. Dean subsequently executed a service request form listing his children as the beneficiaries of his life insurance policy and instructing that beneficial interests be paid to and managed by Kristin Saunders as custodial trustee for the benefit of his minor children. After Dean died, funds from his life insurance policy were distributed to Saunders. Plaintiff filed a complaint seeking declaratory and injunctive relief asking the superior court to declare that Dean's four children were the sole beneficiaries of his life insurance policy. The court granted Defendants' motion for summary judgment, finding that Dean created a valid custodial trust pursuant to the Rhode Island Uniform Custodial Trust Act (RIUCTA) and that the trust was not inconsistent with Dean's obligations under the property settlement agreement. The Supreme Court affirmed, holding (1) Dean created a custodial trust pursuant to RIUCTA; and (2) Dean did not violate the property settlement agreement by designating Saunders as custodial trustee on the service request form.View "Miller v. Saunders" on Justia Law

The Rhode Island Joint Reinsurance Association brought an interpleader action against multiple defendants for the purpose of determining the proper disposition of insurance proceeds. Bank of America, N.A. (BANA), one of the defendants, moved for summary judgment on the interpleader claim and against defendant Genoveva Santana-Sosa’s cross-claim. The superior court granted summary judgment for BANA, concluding that BANA was entitled to the entire amount of the insurance proceeds and that Santana-Sosa was entitled to none of the disputed funds. The Supreme Court affirmed, holding that BANA was entitled to judgment as a matter of law. View "R.I. Joint Reinsurance Ass’n v. Santana-Sosa" on Justia Law

At issue in this case was which party was entitled to insurance funds under an insurance policy on a parcel of property that sustained water damage. Stanley Gurnick and Phoenix-Gurnick, RIGP claimed they owned the property as a result of a foreclosure sale. Navigant Credit Union claimed it was entitled to the funds as the named mortgagee/loss payee in the insurance policy. The superior court decided that Navigant was entitled to the insurance proceeds because the funds were personal property under the insurance contract and Navigant was named a loss payee under that contract. The Supreme Court affirmed, holding that the hearing justice correctly determined that Navigant was entitled to the insurance proceeds. View "R.I. Joint Reinsurance Ass’n v. O’Sullivan" on Justia Law

Plaintiffs purchased a home that a pre-closing inspection revealed had corrosion on the oil heating system in the basement. Although the boiler and oil tank were replaced prior to the sale of the home, the oil feed line buried beneath the concrete floor in the basement was not replaced. After Plaintiffs discovered an oil leak at the feed line, they initiated claims under their homeowners’ insurance policy issued by Defendant. Defendant denied Plaintiffs’ claim. Plaintiffs filed a complaint against Defendant for breach of contract. The trial justice granted summary judgment in favor of Defendant, concluding that Plaintiffs’ claim was caused by gradual corrosion of an oil fuel feed line, not by a sudden or accidental loss, and the claim was therefore barred by the clear and unambiguous terms of the policy. The Supreme Court affirmed, holding that because the undisputed evidence indicated that the damage to Plaintiffs’ property was caused by corrosion, which was not covered by their insurance policy, there were no genuine issues of material fact, and Defendant was entitled to judgment as a matter of law. View "Nunez v. Merrimack Mut. Fire Ins. Co." on Justia Law

Plaintiff filed a complaint against Metropolitan Property and Casualty Insurance Company and other defendants, alleging multiple counts. A jury found Defendants liable for abuse of process and awarded compensatory and punitive damages against each defendant. On May 31, 2012, judgments were entered against Defendants. On August 31, 2012, Metropolitan filed an appeal from the May 31, 2012 judgment, and on September 18, 2012, Plaintiff filed a notice of cross-appeal from the May 31, 2012 judgment. Metropolitan moved to dismiss Plaintiff’s cross-appeal, arguing that it was untimely because it was not filed within the initial twenty-day appeal period that began to run after entry of the August 20, 2012 orders. The trial justice denied Metropolitan’s motion to dismiss, concluding that Plaintiff’s cross-appeal was timely because it was filed within twenty days of Metropolitan’s August 31, 2012 notice of appeal. The Supreme Court affirmed, holding that Plaintiff’s September 18, 2012 notice of cross-appeal was timely because it was filed within the twenty-day period triggered by Metropolitan’s August 31, 2012 notice of appeal. View "Miller v. Metro. Prop. & Cas. Ins. Co." on Justia Law

Defendant's employer had insurance through American States Insurance Policy (ASIC). After Defendant was involved in a car accident, Defendant sent ASIC written notice of a potential claim under ASIC's uninsured/underinsured (UM/UIM) coverage. ASIC did not formally deny the claim but, rather, responded with a declaratory-judgment action, asserting that because Defendant had failed to undertake legal action or to make a written demand for arbitration against ASIC within three years from the date of the accident, her UIM claim against ASIC was time-barred. The U.S. district court entered judgment on the pleadings in favor of ASIC, determining that the three-year limitations period set forth in the policy did not violate public policy. On appeal, the court of appeals certified a question of law to the Rhode Island Supreme Court, which answered by holding that Rhode Island would not enforce the contractual limitations clause in this case because it began to run on the date of the accident rather than the date the insurance contract was breached and was shorter than the statutory limitations period. View "Am. States Ins. Co. v. LaFlam" on Justia Law