Justia Rhode Island Supreme Court Opinion Summaries

The City of Cranston, by and through its tax assessor, valued Plaintiff Narragansett Electric Company's tangible personal property located within that municipality at $23,290,814. Plaintiff appealed the tax assessment. The tax assessor and Tax Board of Review denied Plaintiff's appeal. Plaintiff then filed a complaint in the superior court, naming as defendants Cranston's finance director and its tax assessor. Defendants filed a motion to dismiss the complaint, contending that the superior court lacked subject matter jurisdiction because Plaintiff had not timely filed his appeal to the tax assessor. The hearing justice agreed and granted summary judgment in favor of Defendants. The Supreme Court vacated the judgment of the superior court, holding (1) because Defendants failed to plead as an affirmative defense Plaintiff's noncompliance with a condition precedent in accordance with R.I. Sup. Ct. 9(c), Defendants waived their contention that Plaintiff did not file its appeal with the tax assessor in a timely manner; and (2) therefore, the hearing justice should have exercised the superior court's subject matter jurisdiction and heard Plaintiff's appeal. View "Narragansett Elec. Co. v. Saccoccio" on Justia Law

Because Property Owner failed to pay real estate taxes on his property, the Town held a tax sale of Property Owner's property. Buyer purchased the property after Property Owner defaulted on the action. The superior court subsequently granted Buyer's petition to foreclose Property Owner's right of redemption to the property. Subsequently, a judgment was entered declaring the prior tax sale void and vesting the property back to Property Owner. Property Owner then executed a warranty deed conveying the property to his Sister. Concurrently, a stipulation was entered as an order of the superior court vesting title in the property to Buyer. Thereafter, Property Owner and Sister filed the instant action, seeking a declaratory judgment invalidating the stipulation order. The superior court determined that Buyer was the proper record title holder of the property. The Supreme Court affirmed, holding that a superior court judgment cannot "re-vest" title to property back to a prior owner once that owner has been defaulted in a petition to foreclose his right of redemption and a final decree has been entered. View "Medeiros v. Bankers Trust Co." on Justia Law

Rather than undertaking appeals from the assessment of taxes on its gas assets in accordance with R.I. Gen. Laws 44-5-26(a), plaintiff electric company sought declaratory and injunctive relief directly from the superior court. Plaintiff sued the taxing authorities of most of Rhode Island's municipalities, requesting a declaration that because the municipalities failed to tax plaintiff's gas assets as tangible personal property, they assessed illegal taxes. The trial justice dismissed all but one count of plaintiff's complaint, holding that plaintiff did not file a timely appeal or invoke the court's equitable jurisdiction. The Supreme Court affirmed. Because plaintiff elected to bypass the applicable review procedures and proceed directly to the superior court, plaintiff failed to establish that it had been assessed an illegal tax. Thus, plaintiff could not avail itself of the direct appeal to the superior court. View "Narragansett Electric Co. v. Minardi, et al." on Justia Law