Justia Rhode Island Supreme Court Opinion Summaries

After Deborah Bates-Bridgmon fell at Roch’s Market in West Warwick, Deborah and her husband, Jackie Bridgmon (together, Plaintiffs), filed suit against Defendant, Roch’s Market, for injuries Deborah sustained from her fall. The jury rendered a verdict for Defendants. The Supreme Court affirmed, holding (1) the trial justice did not err by denying Plaintiffs’ motion for a new trial; (2) the trial court did not err by not instructing the jury on the “mode of operation” theory; and (3) this Court declines to consider the merits of adopting the mode of operation theory in light of the circumstances presented in this case. View "Bates-Bridgmon v. Heong’s Market, Inc." on Justia Law

Plaintiff was injured on property owned by two individual owners. The unit owners together formed The 18-20 Woodland Court Condominium Association (Defendant). Just prior to the expiration of the relevant three-year statute of limitations, Plaintiff filed a complaint against the individual unit owners, as well as an entity referred to as “XYZ Company.” Nearly an entire year after the expiration of the statute of limitations, Plaintiff sought leave to file an amended complaint in order to add Defendant as a defendant. A hearing justice granted summary judgment in favor of Defendant, concluding that the statute of limitations had run and that Plaintiff’s original complaint had not tolled the statute of limitations because Plaintiff knew of Defendant’s identity at the time she filed the complaint. The Supreme Court affirmed, holding that the statute of limitations on her claim was not tolled pursuant to R.I. Gen. Laws 9-5-20 because Plaintiff knew the identity of Defendant before the statutory period expired. View "Garant v. Winchester" on Justia Law

Plaintiffs Michael Rose and RC&D, Inc. filed suit against Defendants Stephen Brusini and the law firm Orson & Brusini Ltd. alleging professional negligence and breach of contract. The hearing justice granted summary judgment for Defendants, concluding that there was no evidence of proximate cause linking Defendants’ alleged negligence and any damages Plaintiffs may have suffered. The Supreme Court vacated the judgment of the superior court, holding that Rose submitted sufficient competent evidence to preclude the entry of summary judgment for defendants on a question of fact relating to Defendants’ liability. Remanded. View "Rose v. Brusini" on Justia Law

Scott Cohen’s vehicle collided with the rear of Antonio Soares’s stopped vehicle because Cohen's vision was temporarily impaired by the glare from the morning sun. Cohen waved to Kris Ellinwood, a police officer who was directing traffic at the time, to approach the scene. Cohen assured Ellinwood that everyone was unharmed but did not mention the sun glare. Ellinwood was writing down information in between Cohen's and Soares's vehicles when Andrew Thornley, who did not see Cohen’s vehicle due to solar glare, struck the rear of Cohen’s vehicle, causing Ellinwood to be pinned between Cohen’s and Soares’s vehicles and crushing his legs. Ellinwood filed an action against Cohen, alleging that Cohen negligently failed to warn him of the solar glare, a dangerous condition. The superior court granted Cohen’s motion for summary judgment, concluding that the public safety officer’s rule shielded Cohen from liability. The Supreme Court affirmed, holding that the public-safety officer’s rule barred Ellinwood’s negligence claim as a matter of law because Ellinwood could have reasonably foreseen that he could be struck and injured by another vehicle while coming to Cohen’s assistance.View "Ellinwood v. Cohen" on Justia Law

After Plaintiff’s car was struck from behind by a car operated by Defendant, Plaintiff began experiencing pain in her back and legs, which led to two surgical procedures on her spine. Plaintiff filed a negligence suit against Defendants seeking damages. The jury returned a verdict for Plaintiff and awarded her damages in the amount of $193,584. Plaintiff filed a motion for a new trial and/or additur, contending that the verdict was against the weight of the evidence and that the jury’s damages award failed adequately to compensate her for her injuries so as to shock the conscience. The superior court granted an additur of $428, 416 to the jury award and, if Defendants rejected the additur, granted Plaintiff’s motion for a new trial on the limited issue of damages. Defendants rejected the additur. The Supreme Court affirmed the trial justice’s grant of Plaintiff’s motion for a new trial on the issue of damages, holding that the trial justice (1) adequately set forth sufficient record evidence to support his independent judgment; and (2) was not clearly wrong in determining that the jury’s award of damages was inadequate.View "Rose v. Cariello" on Justia Law

A work van being driven by cable installer Nelson Ovalles collided with a car being driven by Barbara Cayer. Cayer filed a lawsuit against Ovalles and the company on whose behalf Ovalles apparently performed cable-installation work, Cox Rhode Island Telecom, LLC (“Cox”). Cox filed a motion for summary judgment, arguing that it could not be vicariously liable for Ovalles’s actions because it did not own the vehicle or have an employment relationship with Ovalles. The superior court granted the motion. Cayer appealed, contending (1) genuine issues of material fact existed as to whether Ovalles was Cox’s employee at the time of the accident, and (2) the superior court erred by denying her motion to amend her complaint to assert claims against a contractor for Cox. The Supreme Court (1) affirmed the grant of summary judgment in favor of Cox because Ovalles could not be considered Cox’s employee; and (2) denied and dismissed the appeal with regard to the motion to amend, holding that it was improperly before the Court because the order denying Cayer’s motion to amend did not fall within an exception to the final-judgment rule.View "Cayer v. Cox R.I. Telecom, LLC" on Justia Law

Mary Cummings, a participant in a charitable fundraising walk for the benefit of Defendants, was injured when she was struck by a vehicle operated by James Brown, an employee of Bluelinx Corporation. Cummings settled all claims against all Defendants. Brown and Bluelinx then filed suit against Defendants seeking contribution toward the settlement. A jury found that Defendants’s negligence was the proximate cause of Cummings’s injuries and apportioned Defendants’ fault at twenty percent. The superior court subsequently granted Defendants’ renewed motion for judgment as a matter of law, finding that there was not a legally sufficient basis for the jury’s verdict. The Supreme Court affirmed, holding that, as a matter of law, there was no cognizable duty of care owed by Defendants in this case.View "Brown v. Stanley" on Justia Law

Plaintiff was seventeen years old when he and his friends entered certain property reputed to be haunted. As Plaintiff and his companies were attempting to exit the building, a bottle containing sulfuric acid broke and splashed some of its contents onto Plaintiff, severely burning Plaintiff. Plaintiff conceded that he was a trespasser but sued the State under the doctrine of attractive nuisance. After a jury-waived trial, the superior court entered judgment for the State. The Supreme Court affirmed, holding that the trial justice did not err in (1) finding that the attractive-nuisance doctrine did not apply under the circumstances of this case; and (2) not finding that the State shared some comparative fault for Plaintiff's injuries.View "Burton v. State" on Justia Law

After an automobile accident that occurred between Camella Martin and Michael Coyne, Camella suffered a number of injuries. Camella died two years after the accident. Dennis Martin, as executor of the estate of Camella, filed this negligence action against Coyne. After a jury trial, judgment was entered for Defendant. The Supreme Court affirmed, holding (1) the trial justice did not err in granting Defendant's motion in limine to exclude a document from being submitted as evidence because the document was inadmissible hearsay; and (2) the trial justice did not err in denying Plaintiff's motion for judgment as a matter of law or, in the alternative, for a new trial, as the evidence supported the jury's verdict. View "Martin v. Lawrence" on Justia Law