Justia Rhode Island Supreme Court Opinion Summaries

A federally certified organization dedicated to providing comprehensive health and social services to elderly individuals, primarily those eligible for Medicaid, relocated its operations to East Providence and sought a property tax exemption for its new location. The organization asserted that nearly all its participants are low-income elderly and claimed eligibility for exemption under a state statute that provides tax-exempt status for property used for the aid or support of the aged poor, among other categories. After purchasing the property, the organization applied for the exemption, arguing that the statutory language supported its claim. The local tax assessor denied the application, finding that the organization was not one of the specifically enumerated entities—such as a library or a nonprofit hospital—under the statute, and that its mission was not limited to supporting only the aged poor.The organization appealed this denial to the East Providence Tax Board of Assessment Review, which affirmed the assessor’s decision. Subsequently, the organization brought the case to the Providence County Superior Court, where both parties filed cross-motions for summary judgment. The Superior Court found the statute ambiguous and, applying principles of statutory construction, concluded that the exemption applied only to the specific types of entities listed in the statute, all of which must use their property exclusively for the designated purposes. The court granted summary judgment in favor of the tax assessor.On appeal, the Supreme Court of Rhode Island reviewed the statutory language and agreed that it was ambiguous but held that, under Rhode Island law, tax exemption statutes must be strictly construed in favor of taxation. Consequently, any ambiguity must be resolved against the taxpayer. The Supreme Court affirmed the Superior Court’s judgment in favor of the tax assessor. View "Pace Organization of Rhode Island v. Frew" on Justia Law

The plaintiff acquired property in Exeter, Rhode Island, in 1997 and later sought to develop a solar farm on it. To proceed, he needed legal access from a public road. A town map suggested such access via an extension of Estate Drive, but in reality, no road existed there—only undeveloped woods, which the town considered a “paper street.” The plaintiff attempted to clear and gravel the area without town approval, prompting the town to block access and send a cease-and-desist letter. The planning board denied his development application, and the zoning board affirmed. The plaintiff then filed multiple lawsuits, including one seeking a declaration that the disputed area was a public road, and later, claims for due process violations and, after losing on the road status issue, for adverse possession and related theories regarding ownership and access.The Superior Court first denied the town’s motion for judgment on the pleadings in the due process case and then denied the town’s motion to dismiss the adverse possession case. The trial justice reasoned that res judicata and collateral estoppel did not apply because, in her view, the facts and legal theories in the new cases were different from the previously litigated issues, such as whether the area was a public road. She further concluded that the town had acquiesced to separate lawsuits and that Davis was not barred from asserting inconsistent or alternative claims in later litigation.The Supreme Court of Rhode Island reviewed both cases on certiorari. The Court held that res judicata barred the plaintiff’s claims because all arose from the same set of facts concerning access to the disputed area and could have been raised in the initial litigation. The Court further concluded that collateral estoppel and judicial estoppel also precluded the plaintiff’s adverse possession and related claims, as key factual issues had already been determined. The Court quashed the Superior Court’s orders and remanded for dismissal of both cases. View "Davis v. Wood Estates, Inc." on Justia Law

The dispute concerns neighboring property owners in South Kingstown, Rhode Island. The plaintiffs purchased their home in 2010, and the defendant purchased the adjoining lot in 2021. The contested area, approximately 1,134.9 square feet, is included in the defendant’s deed, but the plaintiffs asserted that they had used and maintained it as their own for over a decade, engaging in activities such as planting grass and trees, mowing, and storing items. The defendant’s property was vacant until he moved in, and tensions arose after he objected to the plaintiffs’ continued use of the area and eventually erected a fence.Following the defendant’s acquisition and subsequent dispute, the plaintiffs initiated a suit in the Washington County Superior Court, seeking title by adverse possession, acquiescence, or a prescriptive easement. The Superior Court conducted a bench trial, during which testimony was heard from both parties, the developer, and an expert. After trial, the judge found the defendant’s evidence more credible, particularly noting conversations in which the plaintiffs acknowledged the superior title of the prior owner by inquiring about purchasing the disputed property and seeking permission for certain uses. The court determined that the plaintiffs had not demonstrated hostile possession or a recognized boundary for the requisite ten-year period.The Rhode Island Supreme Court reviewed the Superior Court’s findings under a deferential standard, considering whether the lower court’s factual determinations were clearly erroneous. The Supreme Court affirmed the judgment, holding that the plaintiffs failed to establish by clear and convincing evidence the elements of adverse possession, acquiescence, or prescriptive easement, specifically the requirements of hostility and recognition of a boundary. The Supreme Court also found that the trial court’s findings were sufficiently detailed under the applicable procedural rule. The judgment for the defendant was affirmed. View "Blechman v. Woodward" on Justia Law

The plaintiff owned a vacant parcel in Westerly, Rhode Island, and sought to construct a single-family home. To do so, he needed approval from the Department of Environmental Management (DEM) for an onsite wastewater treatment system (OWTS). He applied for a variance from DEM’s regulations, asserting that his proposed system satisfied the general standard for granting variances. However, DEM denied the variance because the property’s water table was at zero inches from the original ground surface, failing to meet a specific regulatory requirement.After DEM’s denial, the plaintiff did not appeal to DEM’s Administrative Adjudication Division (AAD), arguing that such an appeal would be futile since the AAD purportedly lacked discretion to overturn the denial and could not adjudicate constitutional claims. Instead, he filed suit in the Superior Court, seeking declaratory, injunctive, and monetary relief, asserting both as-applied and facial challenges to the OWTS regulations under the Takings, Due Process, and Equal Protection Clauses of the state and federal constitutions. The state moved to dismiss, arguing failure to exhaust administrative remedies and the lack of constitutional violations. The Superior Court granted the state’s motion, finding that the plaintiff failed to exhaust administrative remedies and the futility exception did not apply.On appeal, the Supreme Court of Rhode Island affirmed the Superior Court’s judgment. The Court held that the plaintiff was required to exhaust administrative remedies for his as-applied challenges and that the futility exception did not apply because the AAD had independent authority to grant variances. For the facial constitutional challenge, the Court determined that the complaint failed to state a claim upon which relief could be granted. The judgment dismissing the complaint was affirmed and the matter remanded. View "DiBiccari v. State of Rhode Island" on Justia Law

A man using a cane visited a public beach in Rhode Island and slipped and fell in the bathroom, allegedly due to sand and water on the floor. He suffered several injuries, including a fractured hip, and required medical attention. He filed a negligence lawsuit against the state, claiming the state failed to maintain the bathroom safely, failed to warn of the dangerous condition, and failed to clean the facility. After his death from unrelated causes, his daughter, as administrator of his estate, was substituted as plaintiff.The Rhode Island Superior Court reviewed the case following extensive discovery. The state moved for summary judgment, asserting immunity under the Rhode Island Recreational Use Statute (RUS), which shields landowners from liability for injuries on land open to the public for recreational use unless the injury results from willful or malicious failure to guard or warn against a dangerous condition. The plaintiff argued there were factual issues regarding the state’s knowledge and actions, relying on complaints about cleanliness and state policies. The Superior Court found no evidence the state had specific notice of the hazardous condition or prior similar incidents, and ruled that the RUS applied, granting summary judgment for the state. The court did not reach the issue of the public duty doctrine.The Supreme Court of Rhode Island reviewed the grant of summary judgment de novo. The Court held that the plaintiff failed to present evidence showing that the state willfully or maliciously failed to warn against or remedy a known dangerous condition. There was no genuine issue of material fact, and the state was entitled to immunity under the RUS. Accordingly, the Supreme Court of Rhode Island affirmed the Superior Court’s judgment in favor of the state. View "Estate of Campagnone v. The State of Rhode Island" on Justia Law

The plaintiffs purchased undeveloped property in Westerly, Rhode Island, in 1999. In 2007, they applied to the Rhode Island Department of Environmental Management (DEM) for permission to install an onsite wastewater treatment system (OWTS), a prerequisite for building a residence on their land. DEM denied their application because the groundwater table on the property was only five inches below the surface, while regulations required a minimum of twelve inches. The plaintiffs did not pursue an administrative appeal at that time.In 2020, more than a decade after the denial, the plaintiffs filed suit in Washington County Superior Court, seeking declaratory relief and compensation for an alleged regulatory taking under state and federal law. They also asserted that the regulation violated their rights to equal protection and due process. The state moved to dismiss the action, contending it was time-barred, the plaintiffs failed to exhaust administrative remedies, and they lacked standing. The Superior Court agreed, holding that the claims were barred by the statute of limitations, that administrative remedies had not been exhausted, and that the plaintiffs lacked standing. The court dismissed the case with prejudice.On appeal, the Supreme Court of Rhode Island reviewed whether the lower court’s dismissal was proper. The Court held that the three-year statute of limitations applied to all claims, and the continuing violation doctrine did not toll the limitations period because DEM’s denial of the permit was a discrete act, not a continuing violation. The Court further found the plaintiffs lacked standing for prospective relief because they did not allege an actual or imminent injury, as any future application might not necessarily be denied. The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. View "Majeika v. State of Rhode Island" on Justia Law

Dorothy Apostolico, after her husband’s death, deeded a house in Cranston, Rhode Island to her three children, reserving a life estate for herself. The deed did not specify who was responsible for property taxes. Dorothy lived in the house until 2023, after which her son Domenic Apostolico resided there. The property did not produce any income during Dorothy’s life tenancy. Domenic paid property taxes during this time and sought reimbursement from his sister, Deborah Pagliaro, for her share of those taxes. After failed written requests, Domenic initiated a lawsuit seeking contribution and unjust enrichment.The Providence County Superior Court first dismissed Domenic’s original claim for contribution but allowed him to amend his complaint. Domenic then filed an amended complaint seeking Deborah’s share of taxes from 2010 onward. He moved for partial summary judgment on the issue of Deborah’s liability for taxes. Deborah objected and filed a cross-motion for summary judgment. The Superior Court, applying the precedent from Koszela v. Wilcox, 538 A.2d 150 (R.I. 1988), ruled that since the property was not income-producing, the responsibility for taxes fell to the remaindermen. The court granted Domenic’s motion as to liability, denied it as to the specific amount, and final judgment was entered for Domenic in the amount of $38,466.42.On appeal, the Supreme Court of Rhode Island affirmed the Superior Court’s judgment. The Court held that, under Rhode Island law, where a life estate property does not produce income, remaindermen—not the life tenant—are responsible for property taxes, regardless of whether the property is developed or the life tenant resides there. The Court also rejected Deborah’s statutory arguments, finding Koszela controlling and the statutes not in conflict with this rule. View "Apostolico v. Pagliaro" on Justia Law

A dispute arose regarding the sale of property located at 301 Harris Avenue in Providence, Rhode Island. The plaintiff, 1100 North Main LLC, sought to purchase property from the Providence Firefighters Realty Corp. (the Firefighters), contingent on the Firefighters acquiring replacement property. The Firefighters entered into negotiations with the defendant, Shoreby Hill Properties, Inc., to purchase the Harris Avenue property. After several communications, the Firefighters signed a draft purchase and sales agreement for the property, but the defendant refused to execute it and reportedly accepted another offer. The plaintiff then filed a complaint seeking declaratory, equitable, or monetary relief based on the alleged contract, and recorded two notices of lis pendens against the Harris Avenue property.In the Providence County Superior Court, the defendant moved to dismiss the complaint, quash the lis pendens, and sought sanctions. The plaintiff argued that the attorneys’ communications constituted assent and that a purported assignment from the Firefighters gave the plaintiff standing. Before the Superior Court justice issued a decision, the plaintiff attempted to amend its complaint to add factual allegations and clarify standing. The trial justice dismissed the complaint and quashed the lis pendens, finding that the allegations failed to satisfy the statute of frauds and did not establish standing. The motion to amend was denied as futile, as no enforceable contract was found.On appeal, the Supreme Court of Rhode Island reviewed whether a binding contract existed under the statute of frauds and whether denial of the motion to amend was proper. The Supreme Court held that the unsigned purchase and sales agreement did not satisfy the statute of frauds and no binding contract existed. The Court affirmed the Superior Court’s dismissal of the complaint, quashing of the lis pendens, and denial of the motion to amend. View "1100 North Main LLC v. Shoreby Hill Properties, Inc." on Justia Law

The plaintiffs owned property in Cumberland, Rhode Island, adjacent to land operated as an automotive recycling facility by the defendants. They alleged that environmental contamination from the facility affected their property. The litigation began in 2006, and after years of procedural developments, the first jury trial in 2012 resulted in a judgment for the plaintiffs. However, the Rhode Island Supreme Court later found that the trial justice had erroneously excluded expert testimony and ordered a new trial.A second jury trial was held in 2020 in the Rhode Island Superior Court. During this trial, plaintiffs’ counsel objected to statements made by defense counsel in his opening, arguing that certain factual assertions were inaccurate. Plaintiffs also objected to the testimony of defense witness Karen Beck, claiming her expert opinion should not include references to a report she had not relied on when forming her initial conclusions. The trial justice issued a curative instruction addressing the opening statement objections and limited Beck’s testimony to certain aspects of the disputed report. The jury returned a verdict for defendants, except for a $10,000 punitive damages award against one defendant, which was later vacated by amended judgment. Plaintiffs appealed, and subsequent procedural delays occurred regarding the transmission of the appellate record.On appeal, the Supreme Court of Rhode Island addressed whether the plaintiffs’ appeal should be dismissed for procedural delay and whether the trial justice erred regarding the curative instruction and Beck’s testimony. The court held that dismissal was unwarranted since plaintiffs timely ordered transcripts and took reasonable steps regarding the record. The court further held that plaintiffs had waived their objection to the curative instruction by failing to object at trial, and that the limitations placed on Beck’s testimony did not constitute an abuse of discretion. The amended judgment of the Superior Court was affirmed. View "Paolino v. Ferreira" on Justia Law

In this case, the defendants executed a promissory note in 2006 for a $28,000 loan from Sovereign Bank, secured by a second mortgage on their property in Smithfield, Rhode Island. The mortgage named Mortgage Electronic Registration Systems, Inc. (MERS) as mortgagee, acting as nominee for the lender and its successors. After a series of assignments, the mortgage was ultimately assigned to the plaintiff. It is undisputed that the original promissory note was lost and that the plaintiff never possessed it. The plaintiff filed a complaint in Providence County Superior Court seeking to foreclose on the property after the defendants defaulted on the loan.The defendants responded by arguing that, under Rhode Island law and relevant precedent, only the party that lost the promissory note could enforce it, and that the plaintiff’s lack of possession of the note precluded foreclosure. The plaintiff moved for summary judgment, asserting that as the assigned mortgagee, it was entitled to foreclose despite not possessing the note. The Superior Court, referencing prior Rhode Island Supreme Court decisions, found no genuine issue of material fact regarding the default and concluded that the mortgagee need not hold the note to foreclose. The court granted summary judgment for the plaintiff, dismissed the defendants’ counterclaims, and authorized foreclosure, subject to further court order.On appeal, the Supreme Court of Rhode Island affirmed the Superior Court’s order. The Court held that under Rhode Island law, a mortgagee with the power of sale may foreclose on a property even if it does not possess the promissory note, so long as it is the properly assigned mortgagee. The Court rejected the defendants’ arguments based on statutory provisions regarding lost notes, reaffirming that possession of the note is not required for foreclosure by the mortgagee. View "Porch Swing Holdings LLC v. Mallory" on Justia Law