Justia Rhode Island Supreme Court Opinion Summaries

The Supreme Court quashed the order of the district court granting the motion to dismiss filed by the State of Rhode Island, acting by and through the Division of Taxation (Division), in this appeal stemming from a series of transactions for the purchase and sale of gasoline, holding that the district court erred in granting the Division's motion to dismiss based on Plaintiff's failure to exhaust its administrative remedies.The tax at issue was levied on a transaction between Plaintiff and another party and was the subject of several transactions between various entities. Plaintiff reimbursed a third-party for the tax assessed on the sale of 300,000 barrels of gasoline and then initiated this action alleging constitutional violations and violations of the Motor Fuel Tax. The trial judge dismissed the case for Plaintiff's failure to exhaust administrative remedies. The Supreme Court reversed, holding that the trial judge erroneously dismissed the action based on Plaintiff's failure to exhaust its administrative remedies. View "Gunvor USA, LLC v. State, ex rel. Division of Taxation" on Justia Law

The Supreme Court quashed the order of the district court dismissing two actions challenging the State Division of Taxation's denial of Plaintiff's claim for a refund of $4,280,039 paid for Motor Fuel Tax assessed on the purchase and sale of 300,000 barrels of gasoline, holding that the the district court erred.Plaintiff purchased 300,000 barrels of gasoline from Defendant. The Division imposed a motor fuel taxes on the gasoline that was charged to Defendant, as the seller of the gas. Defendant sought reimbursement from Plaintiff, which sought a refund from the Division under R.I. Gen. Stat. 31-36-13. The Division denied Plaintiff's claim for a refund on the grounds that Plaintiff did not have a right to pursue a refund. Plaintiff then filed a complaint alleging constitutional violations and violations of the Motor Fuel Tax, among other claims. Plaintiff then appealed the Division's denial of its request for a refund. The hearing officer concluded that Plaintiff's claim was barred by both res judicata and administrative finality. Ultimately, both cases were dismissed. The Supreme Court quashed the decisions below, holding (1) Plaintiff had standing; (2) the trial judge erred in concluding that res judicata barred Plaintiff's appeal; and (3) the doctrine of administrative finality did not apply to bar Plaintiff's claims. View "Apex Oil Co. v. State, ex rel. Division of Taxation" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Respondent, the tax assessor for the City of East Providence, and dismissing Petitioner's complaint brought pursuant to R.I. Gen. Laws 44-5-26(c) alleging that Respondent conducted an illegal property tax assessment for tax year 2012 and an excessive tax assessment for tax year 2013, holding that the superior court did not err.In moving for summary judgment Respondent asserted that Petitioner's claims fell outside the three-month statute of limitations contained in R.I. Gen. Laws 44-5-26 and 44-5-27. Petitioner appealed, arguing that the ten-year statute of limitations generally applicable to civil actions governed its tax assessment challenges. The Supreme Court disagreed and affirmed, holding (1) the General Assembly intended for the three-month statute of limitations to apply to petitions for relief such as the instant petition; and (2) Petitioner's challenges to the illegality of the 2012 and 2013 tax assessments were untimely filed after the three-month statute of limitations had expired. View "Newport & New Road, LLC v. Hazard" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Defendant, in her capacity as the Town of Lincoln's tax assessor, holding that Plaintiff was not entitled to relief on its claims of error.Plaintiff brought this action arguing that Defendant (1) illegally increased the value of Plaintiff's property in light of a solar energy development on a portion of Plaintiff's property for tax years 2019 and 2020, and (2) improperly created a new tax classification not recognized by R.I. Gen. Laws 44-5-11.8(b). The superior court granted judgment in favor of Defendant. The Supreme Court affirmed, holding (1) there was no error in including the presence of a solar energy development as an element of value assessed to real property; and (2) Plaintiff's claim that the tax assessor effectively created a new tax classification for property upon which a solar energy development is located, in contravention of R.I. Gen. Laws 44-5-11.8(b), was unpersuasive. View "Polseno Properties Management, LLC v. Keeble" on Justia Law

The Supreme Court affirmed the order of the district court denying Movants' motions to intervene in an action commenced by Verizon New England Inc. by way of appeal from a decision of the Tax Administrator for the State of Rhode Island, holding that the trial judge did not err.This appeal arose from Verizon's challenge to a final decision of the tax administrator that upheld an assessment of Verizon's tangible personal property (TPP) tax and denied Verizon's request for a lower assessment and a partial refund. Verizon appealed to the district court. The City of Pawtucket and the City of Cranston (collectively, Movants) moved to intervene as of right, claiming an interest in the TPP tax. The district court denied the motions. The Supreme Court affirmed, holding that the trial judge did not err or abuse his discretion in concluding that Movants failed to demonstrate that their interests were not adequately represented. View "Verizon New England Inc. v. Savage" on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment in favor of Plaintiffs in their appeal from the order of the state tax administrator denying a refund with respect to a conveyance tax paid pursuant to a memorandum of agreement, holding that Plaintiffs were entitled to judgment as a matter of law.In this dispute surrounding the conveyance tax Plaintiffs paid to expediently transfer a mall and an associate parking garage, the district court concluded that the transfer of interest in a lease entered into by Plaintiffs was not subject to the conveyance tax under R.I. Gen. Laws 44-25-1(a) because of a tax exemption granted through action by the Rhode Island Economic Development Corporation. The district court granted final judgment in favor of Plaintiffs. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment for Plaintiffs. View "Providence Place Group Limited, Partnership v. State ex rel. Division of Taxation" on Justia Law

The Supreme Court affirmed the final decree of the superior court foreclosing Respondent's right of reception for property sold at a tax sale, holding that there was no error.Petitioner purchased the property at issue in this case at a tax sale. More than one year after the tax sale and the recording of the deed, Petitioner filed a petition seeking to foreclose Respondent's right of redemption. The superior court held a hearing on the petition and determined that Respondent was in default and that Petitioner was entitled to its requested relief. The Supreme Court affirmed, holding that Respondent waived all of the arguments that he raised on appeal. View "E.T. Investments, LLC v. Riley" on Justia Law

In these consolidated appeals, the Supreme Court reversed two judgments of the superior court entered in favor of Petitioners, a group of taxpayers who challenged the City of Providence's tax assessments on their properties for tax years 2014 and 2015, holding that the trial justice erred.The trial justice ruled that a revaluation conducted in 2013 of property values was illegal and invalid and that the tax bills for the relevant tax years shall be revised based on the 2012 revaluation. The superior court entered judgment in favor of Petitioners in excess of $1.5 million. The Supreme Court reversed, holding that the trial justice improperly weighed the evidence and erred as a matter of law in finding that the 2013 revaluation was illegal, invalid, selective, arbitrary, and discriminatory. View "Athena Providence Place v. Pare" on Justia Law

The Supreme Court affirmed the order of the Public Utilities Commission (PUC) approving the interconnection tax which National Grid (NG) charged Petitioners to interconnect to NG's distribution system then paid to the Internal Revenue Service (IRS) as contributions in aid of construction, holding that the PUC did not err.In their petition for the issuance of writ of certiorari, Petitioners asked the Supreme Court to declare the PUC order illegal and unreasonable for purportedly failing to follow a specific IRS ruling and for failing to hold NG to its burden of proof. The Supreme Court affirmed the PUC's order, holding (1) NG was entirely reasonable in believing that it continued to owe the interconnection tax to the IRS and in, therefore, passing that tax on to Petitioners; and (2) the PUC order fully comported with a settlement proposal in this case. View "ACP Land, LLC v. Rhode Island Public Utilities Commission" on Justia Law

In these actions challenging the assessment of alleged illegal real estate taxes on several properties and property owners, the Supreme Court affirmed the judgment of the superior court in favor of Defendants in the declaratory judgment action and denied and dismissed the appeal in the tax appeal action, holding that the Plaintiff did not have standing in either action.Defendants were various officials of the Town of Barrington, Rhode Island; Sweetbriar, LP; and East Bay Community Development Corporation. Plaintiff was the owner of property located in Barrington. Plaintiff filed a complaint appealing the assessment of his property (tax appeal action) and filed a separate declaratory judgment action. In essence, Plaintiff argued that he was forced to pay a higher amount on his taxes because of Sweetbriar's favorable tax treatment under R.I. Gen. Laws 44-5-12 and 44-5-13.11. The hearing justice ruled that Plaintiff lacked standing to bring either action. The Supreme Court affirmed, holding (1) Plaintiff lacked standing to bring the declaratory judgment action; and (2) the hearing justice did not err in determining that Plaintiff lacked standing to challenge Barrington's application of section 44-5-12 and 44-5-13.11 to the Sweetbriar development, along with another project. View "Morse v. Minardi" on Justia Law